Legal citation is a crucial skill for law students and practitioners. It provides a standardized way to reference legal sources, enabling readers to verify information and track legal precedents. Proper citation establishes credibility, supports arguments, and helps avoid plagiarism.
Different citation systems exist, with the and ALWD manual being the most common in the These systems outline rules for citing various legal sources, including cases, statutes, and secondary materials. Understanding the components of citations and their proper formatting is essential for effective legal writing and research.
Purpose of legal citation
Establishes credibility and in legal arguments by referencing specific sources
Enables readers to locate and verify the accuracy of cited information
Supports the principle of by linking current legal analysis to
Importance in legal writing
Demonstrates thorough research and knowledge of relevant legal authorities
Provides context for legal arguments and supports analytical reasoning
Allows readers to distinguish between original ideas and referenced material
Helps avoid plagiarism and ensures proper attribution of legal concepts
Facilitating source verification
Includes specific details (volume, page numbers) for easy location of cited material
Standardizes citation format across legal documents for consistency and clarity
Enables efficient cross-referencing between different legal sources and documents
Supports the adversarial system by allowing opposing parties to scrutinize cited sources
Citation systems
Provide standardized formats for referencing legal materials across various jurisdictions
Ensure consistency and clarity in legal writing and research
Evolve to accommodate new types of legal sources and changing citation practices
Bluebook citation system
Widely used citation manual in U.S. legal practice and academia
Contains comprehensive rules for citing various legal sources (cases, statutes, regulations)
Organized into blue pages for practitioner's notes and white pages for academic writing
Updated periodically to address new citation challenges and source types
ALWD citation manual
Alternative to the Bluebook developed by the Association of Legal Writing Directors
Aims to simplify citation rules and provide more user-friendly formatting guidelines
Focuses on practical application in legal practice rather than academic writing
Gaining popularity in some law schools and legal writing programs
Components of legal citations
Form the building blocks of proper legal referencing
Vary depending on the type of legal source being cited
Combine to create a unique identifier for each legal document or source
Volume numbers
Indicate the specific book or compilation containing the cited material
Typically appear at the beginning of a citation for case reporters or law reviews
May be omitted for sources published in a single volume or online-only publications
Can include series designations (2d, 3d) for multi-series publications
Reporter abbreviations
Represent standardized short forms for legal publications and case reporters
Include both official (U.S., S. Ct.) and unofficial (F. Supp., A.2d) reporter abbreviations
Vary based on and type of legal document being cited
Require familiarity with common abbreviations used in legal writing
Page numbers
Pinpoint the exact location of cited material within a larger document
Appear at the end of a citation, often preceded by a comma
May include specific paragraph or for more precise referencing
Can use "at" before the in certain citation formats
Types of legal sources
Encompass primary and secondary legal materials used in legal research and writing
Require different citation formats based on their nature and authority
Include binding authorities (primary sources) and persuasive authorities (secondary sources)
Case law citations
Reference judicial opinions and court decisions
Include party names, reporter information, court, and year of decision
Format varies for federal and state court decisions
May require in some jurisdictions (official and unofficial reporters)
Statutory citations
Refer to legislative enactments and codified laws
Include title or chapter numbers, section symbols, and statutory compilations
Vary between federal (U.S.C.) and state statutory codes
May require references to specific editions or supplements for up-to-date citations
Secondary source citations
Cover legal treatises, , and other non-binding authorities
Include author names, titles, publication information, and specific page references
Format depends on the type of secondary source (book, article, online resource)
May require additional to explain relevance or content
Citation formats
Provide standardized structures for referencing legal materials
Vary based on the type of legal document and citation system used
Ensure consistency and clarity in legal writing across different jurisdictions
Full citations vs short citations
include all necessary information for first-time references
(short form) used for subsequent references to the same source
used for immediate repeat citations to the same source and page
used for non-consecutive repeat citations, often with a cross-reference
Parallel citations
Provide references to the same legal material in multiple sources
Often required when citing to both official and unofficial reporters
Separated by commas in most citation formats
May include parenthetical information to indicate preferred or controlling source
Pinpoint citations
Direct readers to specific portions of cited legal materials
Enhance precision in legal writing and argumentation
Vary in format depending on the type of legal source being cited
Page numbers
Used for referencing specific pages in books, articles, and case reporters
Typically appear at the end of a citation, preceded by a comma
May use "at" before the page number in certain citation formats
Can include ranges (e.g., 123-125) for citing multiple consecutive pages
Section numbers
Commonly used for citing specific parts of statutes, regulations, or constitutions
Often denoted by the section symbol (§) or the word "section"
May include subsections or paragraphs for more precise referencing
Can be combined with page numbers in some citation formats
Paragraph numbers
Utilized for citing specific paragraphs in judicial opinions or other legal documents
Often enclosed in square brackets or preceded by the paragraph symbol (¶)
Particularly useful for unpublished or electronically reported cases
May be combined with page numbers for more comprehensive citations
Parenthetical information
Provides additional context or explanation for cited materials
Enhances the reader's understanding of the cited source's relevance
Appears in parentheses immediately following the citation
Can include quotes, explanations, or procedural history
Explanatory parentheticals
Briefly summarize the content or holding of a cited source
Often begin with present participles (e.g., holding, stating, explaining)
Should be concise and directly relevant to the point being made
Can include short quotes or paraphrases of key language from the source
Weight of authority
Indicates the precedential value or of a cited source
Uses specific terms (e.g., per curiam, en banc, dictum) to denote authority
May include information about subsequent treatment of a case (overruled, affirmed)
Helps readers assess the relative importance of different cited materials
Signal words
Indicate the relationship between the cited source and the proposition in the text
Appear at the beginning of a citation, before the authority being cited
Help readers understand how the writer is using the cited material
Vary in meaning and usage based on the specific citation system
Common signal words
See introduces sources that directly support the stated proposition
E.g. indicates that the cited source is one of multiple examples supporting the point
Cf. suggests an analogous source that supports the proposition by inference
But see introduces sources that contradict or challenge the stated proposition
Contra signals a directly opposing authority or argument
Proper use of signals
No signal indicates that the source directly states the proposition in the text
Signals should be italicized in most citation formats
Multiple signals can be used together, separated by semicolons
Order of signals typically follows a hierarchy of supportive to contradictory sources
Improper use of signals can mislead readers about the relationship between text and sources
Electronic source citations
Address the increasing reliance on digital legal resources in research and writing
Adapt traditional citation formats to accommodate online and electronic materials
Aim to provide stable and reliable references for potentially ephemeral sources
Require special attention to access dates and URLs for verification purposes
Internet sources
Include URLs or DOIs (Digital Object Identifiers) for online-only materials
Require date of access or last visited date for potentially changing web content
May use permalink or archived versions of webpages for more stable citations
Often include author, title, and website name in addition to electronic locators
Electronic databases
Reference commercial legal databases (Westlaw, LexisNexis) and their unique identifiers
May require specific citation formats provided by the database vendor
Include database name and document identifier or electronic citation (ECF No.)
Often allow for parallel citations to print sources when available
Citation in different legal documents
Adapts citation practices to suit the specific needs and conventions of various legal contexts
Balances comprehensiveness with readability based on the document's purpose and audience
May require different levels of formality or detail depending on the legal setting
Reflects the professional standards and expectations of different legal communities
Academic legal writing
Emphasizes thoroughness and precision in citations
Often requires full citations and extensive use of footnotes or endnotes
May include more secondary sources and interdisciplinary references
Follows stricter adherence to citation manual rules (Bluebook or ALWD)
Court documents
Focuses on primary legal authorities (cases, statutes, regulations)
May require jurisdiction-specific citation formats or local court rules
Often uses in-text citations rather than footnotes for easier reading by judges
Emphasizes recent and binding authorities over older or persuasive sources
Legal memoranda
Balances comprehensive citation with clear and concise writing
May use a combination of in-text citations and footnotes depending on firm preferences
Requires careful attention to short form citations for frequently referenced sources
Often includes to clarify the relevance of cited materials
Common citation errors
Undermine the credibility and professionalism of legal writing
Can lead to confusion or difficulty in locating cited sources
May result from carelessness, lack of knowledge, or outdated citation practices
Require careful proofreading and familiarity with current citation rules to avoid
Improper abbreviations
Using non-standard or outdated abbreviations for reporter names or jurisdictions
Failing to abbreviate words that should be shortened in citations
Inconsistent use of abbreviations throughout a document
Omitting periods in abbreviations where required by citation rules
Incorrect formatting
Misplacing commas, periods, or other punctuation in citations
Failing to italicize case names or as required
Incorrect ordering of citation elements (e.g., putting the court before the year)
Inconsistent use of spacing or capitalization in citations
Citation management tools
Assist legal professionals in organizing and formatting citations
Streamline the process of creating and maintaining bibliographies
Integrate with word processing software for seamless citation insertion
Require initial setup and ongoing maintenance to ensure accuracy
Software options
Dedicated legal citation tools (e.g., Citeus, Lexis for Microsoft Office)
General reference management software adapted for legal use (e.g., Zotero, EndNote)
Built-in citation features in legal research platforms (e.g., Westlaw, LexisNexis)
Custom macros or add-ins for word processors to automate citation formatting
Benefits and limitations
Automate formatting and reduce manual citation errors
Allow easy switching between different citation styles (Bluebook, ALWD)
May struggle with complex or unusual citation formats
Require user vigilance to ensure proper source information input and output
Key Terms to Review (51)
Academic legal writing: Academic legal writing is a structured form of writing used to analyze and communicate legal concepts, cases, and theories in a scholarly context. It often involves thorough research, logical argumentation, and adherence to specific citation styles, aiming to contribute to the broader field of law by exploring legal issues and providing well-supported arguments.
ALWD Citation Manual: The ALWD Citation Manual is a comprehensive guide used for legal citation in the United States, focusing on clarity and consistency in legal writing. It provides specific rules for citing a variety of legal sources, including cases, statutes, regulations, and secondary sources, ensuring that legal professionals can communicate effectively and accurately in their written work.
ALWD Guide: The ALWD Guide, or the 'Association of Legal Writing Directors Guide to Legal Citation,' is a comprehensive reference manual designed to assist legal writers in understanding and applying legal citation rules. It provides a consistent framework for citing legal documents, cases, statutes, and secondary sources, making it an essential tool for students and professionals alike. This guide is widely recognized in the legal field for its clarity and practicality, ensuring accurate communication in legal writing.
Authority: Authority refers to the legitimate power or right to make decisions, enforce rules, and give orders within a legal framework. In the context of legal citation, authority plays a crucial role in determining the reliability and weight of a source when referencing cases, statutes, or regulations. It helps ensure that the citations used in legal documents uphold the standards of credibility and respect established legal precedent.
Binding authority: Binding authority refers to legal sources that must be followed by courts within a jurisdiction when making decisions. This includes statutes, regulations, and case law from higher courts in the same jurisdiction, ensuring consistency and predictability in the law. Understanding binding authority is crucial for interpreting how laws are applied in specific cases, particularly when considering appellate jurisdiction, conducting case law research, and determining proper legal citation.
Bluebook: The Bluebook is a widely used citation guide for legal documents in the United States, providing a uniform system for citing cases, statutes, regulations, and other legal materials. It is essential for ensuring clarity and consistency in legal writing and research, making it easier for readers to locate sources. The Bluebook's detailed rules help legal professionals and scholars properly attribute sources and follow established citation norms.
Bluebook style: Bluebook style is a widely used citation format in the legal field, specifically designed to ensure consistency and clarity when referencing legal documents, cases, statutes, and secondary sources. This system is crucial for legal professionals and scholars as it provides a standardized way to attribute sources, making it easier for readers to locate and verify the cited material. Understanding bluebook style enhances legal writing by promoting professionalism and credibility in legal arguments and analyses.
Brief: A brief is a concise and structured written document that presents legal arguments, facts, and relevant laws to support a position in court. It serves as a tool for attorneys to effectively communicate their case to judges and includes key elements such as a statement of facts, legal issues, and conclusions. A well-crafted brief is essential for both appellate advocacy and persuasive legal writing.
Case citation: Case citation is a standardized method of referencing legal cases, allowing legal professionals to easily identify and locate judicial opinions. This system uses a combination of elements such as the names of the parties involved, the volume number of the reporter, the page number where the case begins, and the year of the decision. Accurate case citation is crucial for legal research, as it provides a clear pathway to authoritative sources and aids in establishing precedent.
Common Signal Words: Common signal words are terms or phrases that help identify the relationships between different parts of legal texts, guiding readers through arguments and reasoning. They play a crucial role in legal citation by clarifying the structure and meaning of cases, statutes, and other legal documents. Understanding these signal words enhances comprehension and interpretation of legal materials.
Court Abbreviation: Court abbreviation refers to the shortened form used to identify specific courts in legal citations. These abbreviations help streamline references and improve clarity in legal documents, making it easier for readers to recognize which court is being cited without spelling out the full name each time. Properly using these abbreviations is crucial for ensuring that legal citations are accurate and conform to established standards.
Court documents: Court documents are official legal papers filed in a court that record the proceedings and decisions of a case. They include pleadings, motions, orders, and judgments, and serve as a critical component of the legal process, ensuring transparency and accountability. Proper legal citation of these documents is essential for referencing cases and understanding the judicial reasoning behind decisions.
Court of appeals: A court of appeals is a higher-level court that reviews decisions made by lower courts, ensuring that the law was applied correctly and that legal procedures were followed. This court does not retry cases but instead focuses on evaluating the legal aspects of the case based on the record from the lower court. Its decisions can create legal precedents that affect future cases, linking it closely to the appeals process and legal citation practices.
Defendant: A defendant is an individual or entity accused of committing a crime or being responsible for a wrongdoing in a legal proceeding. This term is crucial in understanding the roles of parties within a lawsuit or criminal trial, as the defendant is the party that must respond to the allegations made against them. They have the right to present evidence, defend themselves, and challenge the claims brought forward by the plaintiff or prosecution.
Electronic databases: Electronic databases are organized collections of digital data that can be accessed and searched electronically. They play a crucial role in the legal field by providing easy access to a wide range of legal resources, including case law, statutes, regulations, and secondary sources. This accessibility allows legal professionals to efficiently conduct research and gather relevant information needed for legal citation.
Explanatory parentheticals: Explanatory parentheticals are additional information included in legal citations to provide context or clarification about the cited material. They often help readers understand the relevance of the cited case or statute without needing to look it up, serving as a shorthand explanation that enhances comprehension.
F.3d: The term 'f.3d' refers to the Federal Reporter, Third Series, which is a collection of decisions from the United States Courts of Appeals. This series provides a systematic way to cite appellate court decisions and is essential for legal professionals and scholars to reference case law accurately. Understanding this citation format is crucial as it directly impacts how cases are located and understood within the broader legal framework.
Footnote citation: A footnote citation is a method of referencing sources at the bottom of a page, providing additional information, clarification, or credit to the original work. This style helps readers access the source material without interrupting the flow of the main text, and it often includes details like the author's name, title of the work, publication information, and page numbers. Footnotes are crucial in legal writing as they enhance credibility and allow for precise attribution of ideas.
Full citations: Full citations provide complete details about a source, allowing readers to locate the original document. They typically include information such as the author, title, publication date, publisher, and relevant page numbers. In legal contexts, full citations are crucial for referencing cases, statutes, and secondary sources accurately, ensuring proper attribution and aiding in legal research.
Id.: The term 'id.' is an abbreviation for the Latin term 'idem,' meaning 'the same.' It is commonly used in legal citation to refer back to a previously cited source, allowing writers and researchers to avoid repetition while maintaining clarity. This shorthand is especially useful in legal documents where multiple citations to the same source occur in close proximity, streamlining the citation process and enhancing readability.
Inline citation: An inline citation is a method used in legal writing to refer to a source directly within the text of a document. This approach helps to provide immediate context and credibility to the argument or assertion being made by allowing readers to see the reference without having to look at footnotes or endnotes. Inline citations are essential for maintaining clarity and precision in legal arguments, ensuring that readers can easily verify the sources being referenced.
Internet sources: Internet sources refer to various types of content and information that can be accessed online, including articles, reports, blogs, databases, and legal documents. These sources have become crucial in legal citation as they provide a wealth of information that can support legal arguments, offer current perspectives on case law, and present statutes or regulations in a digital format.
Jurisdiction: Jurisdiction refers to the legal authority of a court or government to make decisions and enforce laws over a specific geographical area or type of legal case. It plays a critical role in determining where legal proceedings can occur and which laws apply, affecting everything from individual rights in habeas corpus cases to how cases are researched and cited in the legal system.
Law review articles: Law review articles are scholarly papers written by legal professionals, academics, and students that analyze and critique various legal issues, theories, and cases. They serve as an important form of secondary source in legal research, providing insights and perspectives that help to shape legal scholarship and influence legal practice. These articles often undergo rigorous peer review and are published in law journals, making them a valuable resource for understanding complex legal concepts.
Legal brief: A legal brief is a written document that presents the facts, legal arguments, and relevant laws related to a specific case or legal issue. It is used to persuade a judge or court regarding a particular legal stance, and often includes citations to support the arguments being made, making it an essential tool in legal proceedings.
Legal citation manuals: Legal citation manuals are authoritative guides that provide rules and formats for citing legal documents, cases, statutes, and other legal resources. These manuals ensure consistency and accuracy in legal writing, which is essential for the clarity of communication within the legal profession. They cover various citation styles used in different jurisdictions and fields of law, helping legal professionals and scholars properly reference their sources to maintain credibility and provide verifiable information.
Legal Memoranda: Legal memoranda are detailed documents that outline the legal issues, analysis, and conclusions related to a specific case or legal question. They serve as essential tools for attorneys to communicate their legal reasoning and provide a structured framework for understanding the relevant law and its application to particular facts.
Memorandum: A memorandum is a written document used to communicate information, ideas, or instructions within an organization or legal context. It often serves as an internal document that outlines specific issues, analyses, and recommendations, playing a vital role in legal writing and analysis as well as proper citation practices.
Motion: In legal terms, a motion is a formal request made to a court or judge to obtain a ruling or order on a specific issue during a legal proceeding. This can encompass various requests, such as motions for summary judgment, motions to dismiss, and more. Understanding motions is crucial as they can significantly influence the direction of a case and affect the rights of the parties involved.
Page number: A page number is a numerical designation that identifies the specific page of a document or publication. In legal citation, page numbers are crucial as they guide readers to the exact location of information referenced within legal texts, including cases, statutes, and legal opinions.
Paragraph numbers: Paragraph numbers are numeric identifiers assigned to specific paragraphs within legal documents, statutes, or court opinions. These numbers help in referencing particular sections of a document easily and provide a clear way to locate and cite legal text accurately. They enhance the efficiency of legal writing and research by streamlining communication about specific content without confusion.
Parallel citation: Parallel citation refers to the practice of citing a legal case using more than one source or reporter system to provide a fuller reference. This is especially important in legal writing, as different jurisdictions or systems may publish the same case in different reporters. Using parallel citations helps ensure that readers can locate the case across various reporting systems, enhancing accessibility and clarity in legal documents.
Parallel citations: Parallel citations refer to the practice of providing multiple references for a legal case, which usually includes citations from different reporting systems or jurisdictions. This helps ensure that legal professionals can locate a case through various sources, enhancing accessibility and verification of the law. It also reflects the complex nature of legal research, where cases may be published in different reporter series, and understanding these citations is essential for accurate legal citation and case law research.
Parenthetical information: Parenthetical information refers to additional details or explanations inserted within a legal citation, typically enclosed in parentheses. This information helps clarify the citation by providing context, such as the names of the parties involved, the year of the decision, or other relevant details that aid in identifying the source and its significance.
Persuasiveness: Persuasiveness refers to the ability to convince or influence others through reasoning, arguments, and evidence. It plays a crucial role in legal contexts, as effective persuasion can impact case outcomes, shape judicial opinions, and influence the decisions of juries. A strong understanding of persuasiveness is essential for crafting compelling legal arguments and engaging in effective advocacy.
Pinpoint citation: A pinpoint citation is a specific reference in legal writing that directs the reader to a precise location within a legal document, such as a case opinion or statute. This form of citation is essential in legal contexts, as it allows readers to easily locate particular information, such as a page number or paragraph within a larger text. Using pinpoint citations enhances clarity and precision in legal arguments, ensuring that references are easily verifiable and accessible.
Pinpoint citations: Pinpoint citations are specific references within legal documents that direct the reader to a particular page, paragraph, or section of a source. They enhance legal writing by providing precise locations of the information being cited, ensuring that the reader can easily find and verify the quoted or referenced material.
Plaintiff: A plaintiff is the individual or entity that initiates a lawsuit by filing a complaint against another party, known as the defendant. The plaintiff seeks legal remedy or damages from the court, alleging that the defendant has caused harm or violated their rights. Understanding the role of a plaintiff is crucial in various legal contexts, including civil litigation and products liability cases, where they seek compensation for injuries or damages caused by defective products.
Precedent: Precedent refers to a legal principle or rule established in previous court decisions that is used as a standard for judging future cases. It plays a crucial role in ensuring consistency and predictability in the law, as courts are generally expected to follow the decisions made in earlier cases with similar facts and legal issues. This concept is foundational in various aspects of legal practice, including the interpretation of constitutional provisions, case law analysis, and the crafting of legal documents.
Reporter abbreviation: A reporter abbreviation is a shorthand notation used to reference legal cases, statutes, or other legal materials in a consistent manner, often seen in legal citations. This abbreviation simplifies the process of citing sources, enabling legal professionals to efficiently identify and locate specific cases in legal publications or reports. Understanding reporter abbreviations is essential for anyone working with legal documents, as it streamlines communication and enhances clarity within legal writing.
Section Numbers: Section numbers are specific numerical designations used to identify individual parts of legal documents, statutes, or codes. They help to organize and reference legal texts clearly, allowing readers to quickly locate relevant provisions or rules within a larger body of law. Section numbers are essential for accurate legal citation, enabling practitioners and scholars to efficiently navigate through complex legal frameworks.
Short citations: Short citations are abbreviated references to legal authorities that allow for quick identification of the source without repeating the full citation each time it is mentioned. They are often used in legal writing to maintain clarity and conciseness, ensuring that the document remains readable while still providing the necessary attribution to sources. These citations can vary based on jurisdiction or citation style, but their main purpose is to streamline legal documents and enhance their professional appearance.
Signal words: Signal words are specific terms or phrases used in legal writing and analysis to indicate the relationship between concepts, helping to clarify the structure of an argument or the connections between legal principles. They serve as markers that guide readers through complex legal texts and help to highlight important points, transitions, or conclusions.
Stare decisis: Stare decisis is a legal doctrine that means to stand by things decided. It obligates courts to follow precedents established in previous cases when making decisions in new cases, promoting consistency and predictability in the law. This principle is essential in ensuring that similar cases are treated alike, creating a stable legal environment and influencing the interpretation of the Constitution, the organization of the federal court system, the appeals process, case law research, and legal citation practices.
Statutory citation: Statutory citation refers to the standardized method of identifying and referencing laws or statutes in legal documents. It typically includes the title, chapter, section, and year of enactment, allowing legal professionals to locate the specific legislation quickly and efficiently. This method of citation is essential for maintaining clarity and consistency in legal writing and research.
Statutory Citation: Statutory citation is the system used to reference specific laws or statutes in legal documents and discussions. These citations provide a standardized format that helps identify the source of a law, allowing for easy access and verification. By following specific conventions, statutory citations promote clarity and consistency in legal writing, ensuring that readers can quickly locate the statutes being referenced.
Supra: The term 'supra' is a Latin word meaning 'above' or 'over,' commonly used in legal citations to refer to a source that has been previously mentioned. It helps streamline legal writing by preventing redundancy, allowing authors to reference earlier sources without repeating full citations. This term plays a vital role in maintaining clarity and conciseness in legal documents, facilitating easy navigation for readers.
Supreme Court: The Supreme Court is the highest federal court in the United States, established by the Constitution, which has the ultimate authority in interpreting laws and the Constitution itself. It plays a crucial role in the judicial system, particularly in cases involving significant constitutional issues, and its decisions set important precedents that guide lower courts. The Supreme Court hears appeals on a limited basis, focusing on cases that have broad legal or societal implications.
U.S.: The U.S., or the United States, is a federal republic comprising 50 states, a capital district, and several territories. It is recognized for its legal system based on the Constitution, which serves as the supreme law of the land and outlines the framework for governance, rights, and justice.
Volume number: The volume number refers to the numerical designation assigned to a particular collection of legal documents or publications, such as law reports or legal journals, indicating the chronological grouping of cases or articles. This number is essential for accurate legal citation, as it helps to locate specific content within a series of published materials, ensuring clarity and precision in legal references.
Weight of authority: Weight of authority refers to the persuasive power or influence that a particular legal source or precedent holds within the legal system. It is essential in legal citation, as it helps to determine how much credence a court or practitioner should give to a source, like case law, statutes, or secondary materials, when making legal arguments or decisions.