Maybe All That Law Review Cite Checking Is Good For Something
Congratulations go out to Blogdenovo.org, which has just hit a milestone this blog never achieved: it's been cited in a Ninth Circuit dissent. (Hat tip to Volokh [1]) Better yet, the lucky blog gets mentioned as authority before the Harvard Law Review.
Of course, the opinion seems to imply that law student Sean Sirrine is a member of the defense bar. This will surely be news to his compatriots at De Novo, a blog that tries to keep a "law students only" policy. (Hence Jeremy Blachman and Chris Geidner are ex-members.) Such a misstatement leads one to think that the citation might have been a bit of a mistake on the part of the judge (or some poor clerk).
How did this happen? As of this writing, De Novo is the top hit for the term "U.S. v. Scott." I'd guess that this has something to do with it.
Entertainingly, not only was the citation factually incorrect, but it doesn't follow the Bluebook's horrible citation format for blogs. Not that the latter isn't all to the good.
[1] Disclosure: I've done some small writing for De Novo from time to time and give the occasional bit of tech support. Entry edited slightly for grammar and style.