UNITED STATES DISTRICT COURT
                      Northern District of Ohio
                      United States Courthouse
                         2 South Main Street
                         Akron, Ohio  44308

                          February 26, 1997

VIA FACSIMILE ONLY

Appellate Court and Circuit
  Administration Division
ATTN: ABA Citation Resolution
Suite 4-512
Administrative Office of the U.S. Courts
Washington, D.C. 20544

RE: ABA Resolution on Citations

Dear Sir or Madam,

     I write to voice my opinion regarding the American Bar 
Association's resolution calling for developing of a standard 
citation system for state and federal court opinions.

     In my view, it is unworkable and undesirable for several 
reasons.

     First, paragraph 1(A) calls for sequential numbering of 
decisions. This might work for appellate courts which issue their 
opinions centrally, but it will certainly not work for multi-judge 
district courts where each judge issues his or her own orders and 
opinions.

     Second, the proposed standard form of citation in paragraph 1(E) 
does not appear to comport with the new Sixth Circuit electronic 
citation form. Presuming that other circuits may also have their own 
electronic citation form, the newly suggested form would require all 
of those circuits to re-do their citations.

     Third, and, in my view, most important, the proposed citation 
form if adopted, would have serious consequences for sole 
practitioners and small law firms that cannot afford access to 
electronic databases. Requiring parallel electronic citations for all 
cited case authorities in briefs, etc. would be absolutely cost-
prohibitive for such attorneys.

     I believe citation to the West Publishing Co. reporters provides 
sufficient uniformity. Where opinions are also reported on electronic 
databases, those services can simply cite to West as has been done to 
date. Adding an additional electronic database citation simply adds 
needless and expensive complexity without adding much, if any, 
efficiency.

     I add my voice to any and all persons who oppose the ABA's 
resolution.

     Thank you.

                                   Yours very truly,

                                   David D. Dowd, Jr.
                                   Judge
                                   U.S. District Court
                                   Northern District of Ohio
                                   Akron, Ohio