This Citation Does Not Exist

In 2019, engineer Phillip Wang launched a website called "This Person Does Not Exist," which harnessed the StyleGAN AI system to generate realistic-looking photographs of nonexistent people. Although Wang's original website is now defunct, scores of similar sites do exist, including a variation of This Person Does Not Exist and a variety of generators designed for such diverse uses as helping programmers look busy at work, creating a geography guessing game out of Google Street View, and introducing made-up dictionary definitions into the lexicon.

Just a few years later, large language model (LLM) chatbots are the hottest trend in generative AI technology, with OpenAI's ChatGPT, Microsoft's Bing Chat (powered by ChatGPT), and Google's Bard the best-known of their kind. It's easy to see their appeal – type a quick prompt and almost instantly generate a wall of convincing-sounding text, complete with citations.

Sound too good to be true? Alas, it certainly can be. Since the public unveiling of ChatGPT and similar systems, many users have noticed that some of the supporting citations…well, just don't exist. In most cases, these will appear to be a perfectly plausible book, article, and even court opinion or statute citation, until a researcher attempts to actually retrieve the cited material. These dead-ends are called "hallucinations" by programmers (or "hallu-citations," as coined by USC professor Kate Crawford) and have become a growing problem for researchers as these systems explode in popularity.

The New York Times reported earlier this month on the perils of "When A.I. Chatbots Hallucinate." Commentators have highlighted damaging falsehoods from hallucinated biographies, including for a law professor falsely implicated for sexual harassment and an Australian mayor implicated in the bribery scandal for which he had actually been the whistleblower.

Google's Bard, which just removed its waitlist last week, contains a clear warning of the potential for inaccurate information and encourages its users to double-check results: Bard will not always get it right: Bard may give inaccurate or inappropriate responses. When in doubt, use the "Google it" button to check Bard's responses. (Bard results will also include links to sources from which the response is drawn, at least in the case of a direct quotation.) OpenAI similarly acknowledges the concerns about inaccuracies: ChatGPT sometimes writes plausible-sounding but incorrect or nonsensical answers. Fixing this issue is challenging...

These tools will continue to improve over time, and the potential applications for quick search, summary, and drafting assistance are truly exciting. For legal research, Lexis has recently announced the planned launch of Lexis+ AI, which will roll out to law school faculty later this summer. Other tools to watch in this space include Casetext’s CoCounsel, powered by GPT-4 and unveiled in March. As these tools continue to develop, though, researchers need to remain aware of the potential inaccuracies that may appear in results, especially in these early days.

Of course, researchers have always had to be on the lookout for erroneous citations (whether due to sloppy notetaking by authors, poor cite-checking by editors, or transcription errors by typists and publishers). But now, it's more important than ever to double-check cited sources for accuracy, in order to prevent spreading any nonexistent citations.

So where can a researcher confirm the existence of a cited source? There is no one-size-fits-all answer, but a few bookmarks to keep handy for verification purposes include:

• The existence of a particular book title can usually be verified via a search of WorldCat.org and/or Google Books. To obtain a copy for substantiation purposes, consult the Duke Libraries Catalog.
• Journal article citations can likely be verified quickly via the library's Articles search, E-Journals title search, and/or Google Scholar. (Tip: When using Google Scholar, visit Settings > Library Links to ensure "Duke University Libraries – Get it at Duke" is enabled to allow you to log in to many paywalled full-text resources with your NetID.)
• Court opinions from US jurisdictions can usually be retrieved in your preferred legal research service (e.g., Westlaw, Lexis, Fastcase). Two free resources to try accessing the full text of case law include Google Scholar and the Harvard Caselaw Access Project. Note that some time periods and jurisdictions may not be available, depending on which source you choose.
• For statutes, try to retrieve by citation in your preferred legal research service. Many jurisdictions provide free access to current codes and historical session laws on their websites, linked at Cornell's Legal Information Institute. If searching by citation fails, search selected keywords from the quoted text.
• To locate content from cited websites that now appear to be defunct, try entering the URL into the Internet Archive Wayback Machine.

For help with locating other specific types of materials that you discover in your research, be sure to Ask a Librarian.

Summer Access to Research Resources

Whether you are graduating from Duke Law this May or continuing your legal studies next year, your access to legal research services and other campus databases may change this summer. Below is a summary of policies for the major legal research databases that you might wish to access over the summer.

Continuing Students

• Westlaw allows continuing students to use Thomson Reuters products, including Westlaw® and Practical Law, over the summer for non-commercial research (i.e., "to gain understanding and build confidence in your research skills, but you cannot use them in situations where you are billing a client"). Examples of permissible uses for your academic Westlaw password include summer coursework, Research Assistant assignments, research for journal/law review or moot court, non-profit/clinic work, or an externship sponsored by the school. Your Westlaw summer access will continue automatically - no action is needed on your part.
• Lexis: All returning students have automatic, unlimited access to their Lexis law school IDs for the entire summer. Law School Lexis IDs may be used for non-commercial purposes, as well as commercial purposes if your employer permits such use.
• Bloomberg Law: Your Bloomberg Law access continues over the summer automatically. IDs may be used for non-commercial purposes, as well as commercial purposes if your employer permits such use.

Graduating Students

• Westlaw: You may opt in to Thomson Reuters products, including Westlaw and Practical Law, for six months after graduation for non-commercial use (through November 30, 2023). This "Grad Elite" access allows 60 hours of usage per month to gain understanding of legal topics, build your research skills, and prepare for your bar exam.
  In order to activate Grad Elite access, follow the instructions on the email received directly from West, or register online by logging into https://lawschool.tr.com and clicking on your name to access Grad Elite. Please note that if you reach your 60-hour Grad Elite limit before the end of a calendar month, you will not be able to access Westlaw again until the start of the following calendar month. You may wish to use folders within Westlaw and email the contents to yourself before logging off if you are close to your 60-hour limit for a particular month.
• Lexis: Spring 2023 graduates will have automatic access to Lexis+ via their Lexis law school IDs until December 31, 2023. Spring graduates have access to most of the same content and features available during law school, excluding public records, Law360, Practical Guidance and Lexis for Microsoft Office. Graduates working in the non-profit sector may also apply for a LexisNexis ASPIRE ID which lasts 12 months beyond graduation. Learn more about the LexisNexis Graduate programs and/or apply for an ASPIRE ID.
• Bloomberg Law: Access to Bloomberg Law continues automatically for six months after graduation (through November 30, 2023). Graduated students may be limited in their ability to retrieve docket filings marked "Request," update dockets, or set up docket tracking. Graduates may download docket items already uploaded in the Bloomberg system (labeled "View").

Access to most other Duke University research databases will expire upon graduation, when your status in Duke's directory changes to "Alumni." Recent graduates who register with the Duke Alumni Association for a OneLink account receive remote access to selected databases (including ProQuest ABI Inform, JSTOR, RefWorks citation management, and several video databases).

For questions about using legal research services or other Law Library/University electronic resources this summer, be sure to Ask a Librarian.

A Century of the American Law Institute

2023 marks the 100th anniversary of The American Law Institute (ALI), whose mission is "to clarify, modernize, and improve the law" through its highly respected publications and projects. While the Restatements of the Law are likely the ALI's best-known publications (due to their frequent citation and endorsement by courts, which can "adopt the Restatement view" of a particular topic), the ALI has also developed important codifications like the Model Penal Code and the Uniform Commercial Code, among other publications, studies, and projects.

The Goodson Law Library is joining the celebration of the ALI Centennial with an exhibit on Level 3 of the Library. From Monday, March 20 through the end of spring semester classes, visit the main floor of the library and the Riddick Rare Books and Special Collections Room (accessible on weekdays from 9:00 am to 5:00 pm) to learn more about the history of the ALI and of Duke Law faculty contributions to their seminal publications.

The Library is also co-presenting an ALI Centennial panel discussion with the Office of the Dean on Thursday, April 6 in room 3037 at 12:30 pm. Our distinguished panel of experts includes:

• David F. Levi (Dean Emeritus, Duke Law): ALI President
• Andrew Gold (Professor, Brooklyn Law; Duke JD’98): co-editor of The American Law Institute: A Centennial History (forthcoming from Oxford University Press)
• Deborah A. DeMott (Professor, Duke Law): Reporter, Restatement (Third) of Agency
• Brandon L. Garrett (Professor, Duke Law): Associate Reporter, Principles of the Law, Policing

For additional information about the history and work of the American Law Institute, check out the timeline website for The ALI’s First Century. A pre-publication draft of Prof. DeMott's chapter in the forthcoming Centennial History volume is also available for download on SSRN. The Duke University community can view current and past drafts of ALI publications, codifications, and other projects in HeinOnline's American Law Institute library. To locate particular ALI publications, or for help accessing materials mentioned here, be sure to Ask a Librarian.

In Memoriam: Public Papers of the Presidents (1957-2022)

The end of 2022 also marked the end of a long-running government publication series, when the Administrative Committee of the Federal Register published a rule announcing the discontinuation of the Public Papers of the Presidents of the United States.

The Public Papers book series began in 1957, after the National Historical Publications Commission recommended the creation of an official government publication that brought together the various speeches, remarks, and writings for a particular presidential administration. Prior to the Public Papers, access to presidential materials was less consistent and less timely, with some materials published decades later at the direction of Congress (such as Richardson's 20-volume set A Compilation of the Messages and Papers of the Presidents, 1789 – 1897), and other materials privately published (such as the Public Papers and Addresses of Franklin Delano Roosevelt). The Public Papers has covered the administration of every U.S. president from Herbert Hoover to Barack Obama (minus FDR, due to the private publication of his papers before the launch of the series). Effective with the rule on December 29, 2022, the Government Publishing Office noted that the final volume of the Obama series would be the publication's last.

It is somewhat fitting to cease the Public Papers with President Obama, as his administration also oversaw a shift in the Compilation of Presidential Documents publication whose contents form the corpus of the Public Papers. Formerly printed as the Weekly Compilation of Presidential Documents, the Obama administration changed to an online-only Daily Compilation of Presidential Documents in 2009. In its final rule, the agency noted that the Daily Compilation access is timelier and enjoys wider reach than the printed Public Papers, which have been distributed for free to participating libraries (including Duke Law) through the Federal Depository Library Program for half a century.

What does this change mean for researchers? The current Bluebook prefers citation to Public Papers of the Presidents where available; going forward, it appears that the online Daily Compilation of Presidential Documents will become the preferred citation for most post-Obama presidential documents, and the Code of Federal Regulations will likely remain the preferred source for executive orders and presidential proclamations.

• Historical editions of the Public Papers can be found in GovInfo, HeinOnline's U.S. Presidential Library, and in the Law Library's Documents collection Doc. AE 2.114.
• Historical Compilations of Presidential Documents can be found on GovInfo (back to 1993) HeinOnline’s U.S. Presidential Library (back to 1965), and in the Law Library's Documents collection Doc. AE 2.109 (1965-2000).
• Historical editions of the C.F.R. can be found in GovInfo (back to 1996); HeinOnline's Code of Federal Regulations Library (back to 1938), and in the Law Library's Documents collection Doc. AE 2.106/3. (Note that historical volumes of CFR Title 3, which contain the presidential materials, are shelved with the current CFR edition on Level 3, in the Stevens Federal Area.)

For more information about presidential materials and the administrative rulemaking process that ended the Public Papers, check out the library's research guide to Federal Administrative Law or Ask a Librarian.

News You Can Use

"This content is available only to subscribers." "You have used your allotment of free articles this month." "Buy a day pass or subscribe to access this content." If you usually give up after you receive pop-ups like these on a news website, you might be missing out on alternative paths to accessing the full text of the stories you want through Duke's many subscription databases. While some sources do require pre-registration or a few additional steps to reach the same article, the access to the stories you want to read is often worth the extra effort.

First, be aware of the complimentary direct access that the Duke Law and Duke University community enjoys to several major news outlets: 

• New York Times: Current members of the Duke Law community may join the Law School group account to receive complimentary access to NYTimes.com content on the web and selected smartphone apps. Student accounts will last until December of their graduation year; faculty and staff accounts require renewals annually. Register or renew an account while connected to a networked computer in the Law School building (such as the library workstations) or remotely while connected to the Law School's VPN (be sure to select the Library Resources option at sign-in, rather than Default). Then type "Duke" under "Find School" and select "Duke University School of Law." 
• Financial Times: Current members of the Duke Law community may join the Duke Law Library "group subscription" by registering an account at the Duke Law site for FT.com using their Duke email address. 
• Wall Street Journal: Through a partnership between the Fuqua School of Business's Ford Library and the Goodson Law Library, individual account access to WSJ.com is available to all current Duke University students, faculty, and staff who register with a duke.edu email address. Student accounts last for 90 days past graduation. To register, visit the Ford Library info page  and follow the instructions.

Third-party databases also offer alternative full-text access to the content of many of your favorite news sites. To locate options for reading a particular newspaper or magazine, try a search of the Duke University Libraries E-Journals list or Duke University Libraries Catalog. For example, Raleigh's News & Observer and the Durham Herald-Sun both offer their current contents in the America's News database, making those locked website stories just a few extra clicks away. (Note that the options in America's News may include both HTML text versions of stories as well as images of the actual newspaper in PDF; for these examples, the E-journal search results dating from 2018-present provide the image-based access. You can view the options for a particular title in the database by clicking "See Related sources.")

Other popular sources that you can access via this E-journals search method include The New Yorker and The Chronicle of Higher Education.

For the Law School community, also keep in mind that Lexis and Westlaw offer additional access to various newspapers and websites. For example, Westlaw offers the recent stories from Business Insider, while Lexis features the full text of Inc.com. Because these databases are only available to the Law School community, results from these services do not appear on the campus-wide E-journals list search, but it can be worth searching separately to see if a desired source appears in the legal research services. (Note that an E-journals search result in Nexis Uni, the campus-wide version of Lexis, is a good indicator that it will be available in the Law School version of Lexis as well.) 

For help with accessing the full text of other news resources when you hit a paywall, be sure to Ask a Librarian!

Winter Break Reading Recommendations

As the days get shorter and the nights get colder, winter break is a great time to curl up with a good book! We asked the staff of the Goodson Law Library to share some recommended reading – either books they've enjoyed recently or titles they're looking forward to reading next. If you need some inspiration for your to-be-read pile, check out our seven winter 2022 recommendations below.

What We Liked

Candice Millard, River of the Gods: Genius, Courage, and Betrayal in the Search for the Source of the Nile (2022). (Request a print copy!): "A gripping account of adventure, personal rivalry, and innumerable obstacles in the search for the headwaters of the Nile by a formerly enslaved man, a British aristocrat, and the English translator of One Thousand and One Nights and the Kama Sutra. In this epic tale, Millard pulls together the history of British imperialism, literature, science, and geography (not to mention disguises, burrowing beetles, and Dr. Livingstone). I couldn't put it down!" – Laura Scott, Assistant Director for Reference, Clinics & Outreach and Senior Lecturing Fellow

 

Stephen Greenblatt, The Swerve: How the World Became Modern (2011). (Request a print or Kindle copy!) "This book was such a pleasure to read. It is both a historical mystery story and a fascinating introduction to an ancient poem, Lucretius' On the Nature of Things, which was astonishingly ahead of its time." – Don Hopkins, Data Scientist

 

Erika Krouse, Tell Me Everything: The Story of a Private Investigation (2022). (Request a print copy!) "This memoir of a rookie PI's work for an attorney on a Title IX lawsuit against a university athletics program reads more like a novel. It's a fascinating view into a part of legal practice that you don't hear much about in law school, vividly told by an author whose own past trauma informs her approach. (Content warnings: sexual assault & child abuse.)" – Jennifer L. Behrens, Associate Director for Administration & Scholarship and Senior Lecturing Fellow

Marlon James, Moon Witch, Spider King (2022). (Request a print or e-book copy!): "I'm currently reading the second novel in the Dark Star Trilogy. Set in ancient Africa, Moon Witch, Spider King dives into the origin story of Sogolon, the Moon Witch. I am excited to continue diving deeper into the fantasy world from the first novel in the trilogy, Black Leopard, Red Wolf.” –Julie Wooldridge, Research Services Librarian and Senior Lecturing Fellow

 

What We’re Excited to Read Next

Nina Totenberg, Dinners with Ruth: A Memoir on the Power of Friendships (2022). (Get on the hold list!) "This book was written by someone I have a lot of admiration for, about someone I have a lot of admiration for. Haven't read it yet, but will do so one of these days, over dinner." – Jane Bahnson, Assistant Director for Research & Instruction and Senior Lecturing Fellow

Neil Gaiman, Neverwhere (1997). (Get on the hold list!): “I'm excited to start Neverwhere because I liked American Gods, and the reviews for this book are very good: it is one of NPR's Top 100 Science Fiction and Fantasy books of all time!” –Chelsey McKimmy, Research Services Librarian and Lecturing Fellow

 

Michelle Zauner, Crying in H Mart: A Memoir (2021). (Request a print or e-book copy!). "I would like to read this critically-acclaimed memoir by musician Michelle Zauner (of Japanese Breakfast), about reconnecting with her Korean heritage after the death of her mother. I think that her reflections on grief and loss will be relatable to a wide audience, although they (and I!) may want to save it until after the holiday season." – Alex Zhang, Archibald C. and Frances Fulk Rufty Research Professor of Law, Associate Dean of Information Services, and Director of the J. Michael Goodson Law Library

Finals without Fear

Hard to believe that fall finals are just around the corner! As you prepare for a marathon of studying and essay-writing, fill in those outlines and clarify confusing concepts with the help of the Law Library. The Library offers access to hundreds of online study aids and supplements that can help you get ready for finals:

• The West Academic Library Study Aids provides full-text access to hundreds of study aids, treatises, audio lectures, and flash card sets published by West Academic. Series available include Acing, Concepts and Insights, Hornbooks, Nutshells, Black Letter Outlines, Legalines, Sum and Substance audio, and many more.
• The Aspen Learning Library (formerly known as Wolters Kluwer Study Aid Library) contains nearly 200 study aids published by Aspen Publishing. Available series include Examples & Explanations, Glannon Guides, Emanuel Law Outlines, and more.
• Elgar Advanced Introductions to Law is a small but mighty collection of brief, accessible texts on over two dozen topics, particularly strong in comparative and international law.

Additional study aids are available in the library's print collection. Find titles and call number/locations by searching the Duke Libraries Catalog.

The Library collection also includes guides to studying for, and writing, law school examinations. The Law School Success handout in the online Orientation Packet describes a number of these titles in the Exam Preparation section. A catalog search for the subject heading "Law examinations -- United States" will return print and online book results with guidance for studying, outlining, and writing exam answers

Please note if borrowing print materials that items are subject to recall requests by other borrowers, and that demand is particularly high during exam period. As a result, your due date may be shortened, and you will be notified by email of any recall requests.

How else can the library help you prepare for exam period? Foam earplugs are available at the service desk to help you focus, courtesy of CALI. CALI also provides students with access to hundreds of online tutorials, free e-books, and other materials. Registration codes are available in Sidebar on level 3 (along with limited quantities of CALI's interlocking brick highlighters!), or via the download link with NetID and password.

For help with locating or accessing the materials described here, be sure to Ask a Librarian.