UNITED STATES DISTRICT COURT
                 FORTHE WESTERN DISTRICT OF MICHIGAN
                         416 U.S. Courthouse
                    Grand Rapids, Michigan  49503

                          February 28, 1997 
 
Ms. Joan Countryman 
Appellate Court and Circuit Administration Division 
Attn: ABA Citation Resolution 
Ste. 4-512 
Administrative Office of the U.S. Courts 
Washington, D.C. 20544 

RE: Comments concerning ABA Resolution in Universal Citation System 

Dear Ms. Countryman: 

     In responding to the Administrative Office February 20th 
memorandum this writer has searched in vain for any prior 
communication evidencing a "problem" that needed "fixing" relative to 
the present citation system. 

     A cursory review of the Federal Supplements reveals there are no 
standards concerning what opinions are published or unpublished. 
Apparently the law publishers print everything submitted. This should 
not be. Case after case in the Federal Supplements concern the fact 
intensive granting or denying of dispositive motions carrying no new 
legal principle in application or genesis. Thus, the 'data bases' are 
cluttered with unimportant decisions becoming elevated to 'head 
notes' for citation which give no precision in law application 
whatever. This 'Law of headnotes' does nothing to advance legal 
scholarship, except help build strings of citations. 

     To require additional citations beyond the case number with the 
numbering of each paragraph is an onerous burden upon court staff 
with no measurable benefit to the court and benefit only to the 'date 
base' private publishers. This cost shifting from the private to the 
public sector is clearly unwarranted. 

                                   Sincerely, 
 
                                   Robert Holmes Bell 
                                   United States District Judge