I'm not a monster fan of the California Style Manual. Though I readily concede that I don't have a good reason for that distaste. I'm just used to the Bluebook, which is what's generally used both in federal court as well as in academia (as well as in numerous other state courts). So having to navigate something different imposes a (very slight) degree of pain.
So when I read this opinion this afternoon, I wasn't sure if my critique was with the California Style Manual or elsewhere. The relevant portion of which reads:
"Rather, Fidelity relied on inapposite out-of-state authority, namely: State v.
Sedam (2005) 34 Kan.App.2d 624 [122 P.3d 829] (Kansas); United States v. King (7th
Cir. 2003) 349 F.3d 964 (King) and United States v. Gambino (1992) 809 F.Supp. 1048
Okay, I understood that the first case was from Kansas, and the second case was from the Seventh Circuit. Both, obviously, are outside California.
But what about Gambino? I get that it's a federal case, so not necessarily binding on the Court of Appeal. Nonetheless, I wanted to know where it was from. Is this a federal case in California, or elsewhere? The citation didn't tell me. Neither in this place nor in the other portions of the opinion in which that case was mentioned.
If that was because the California Style Manual doesn't require a reference to the particular district court, well, so much the worse for the Manual. Another reason to dislike it.
But then I looked it up. And, as I suspected, the Style Manual does indeed say to include which district court in the citation. So I resorted to Mr. Google. Turns out it's the S.D.N.Y.
So the omission was Justice Nares', not the Manual.
Which is not to say how one cites a case is the most pressing issue in the universe. Far from it.
But still. Include the "S.D.N.Y."