When Is It Appropriate to Cite to Wikipedia?

Wikipedia.jpgWikipedia, the online encyclopedia that anybody can edit, is frequently getting cited by courts and academics. The New York Times reports:

A simple search of published court decisions shows that Wikipedia is frequently cited by judges around the country, involving serious issues and the bizarre — such as a 2005 tax case before the Tennessee Court of Appeals concerning the definition of “beverage” that involved hundreds of thousands of dollars, and, just this week, a case in Federal District Court in Florida that involved the term “booty music” as played during a wet T-shirt contest.

More than 100 judicial rulings have relied on Wikipedia, beginning in 2004, including 13 from circuit courts of appeal, one step below the Supreme Court. (The Supreme Court thus far has never cited Wikipedia.)

“Wikipedia is a terrific resource,” said Judge Richard A. Posner of the United States Court of Appeals for the Seventh Circuit, in Chicago. “Partly because it so convenient, it often has been updated recently and is very accurate.” But, he added: “It wouldn’t be right to use it in a critical issue. If the safety of a product is at issue, you wouldn’t look it up in Wikipedia.”

Paul Caron writes:

I asked my crack research assistant, Drew Marksity, to determine how many times law professors have cited Wikipedia in law review articles. Using Westlaw’s JLR database, Drew found that 545 articles cite Wikipedia. (An additional 125 articles mention Wikipedia but do not cite it as authority.)

Brian Leiter writes:

[Caron] discreetly, does not list the names of the authors of these articles, all of whom should presumably be blacklisted from scholarly careers (unless, of course, the citation was in the context of, “Wikipedia reflects the popular prejudice that…” or “Wikipedia records this error as though it were fact, proving yet again the unreliability of the Internet…” or “In this instance, actual scholarly sources confirm what Wikipedia reports…”).

Inside Higher Ed reports that some schools are barring students from citing to Wikipedia:

While plenty of professors have complained about the lack of accuracy or completeness of entries, and some have discouraged or tried to bar students from using it, the history department at Middlebury College is trying to take a stronger, collective stand. It voted this month to bar students from citing the Web site as a source in papers or other academic work. All faculty members will be telling students about the policy and explaining why material on Wikipedia — while convenient — may not be trustworthy.

When is it appropriate to cite to Wikipedia?

I am generally against categorical bans, as the issue really depends upon the context. I did a search of some of the Westlaw citations, and below the fold I’ll list a few.

1. From 59 Stan. L. Rev. 257, in a footnote: “For an overview of the use of modification or “mod” software in computer gaming, see generally Mod (Computer Gaming), WIKIPEDIA, http:// en.wikipedia.org/wiki/Mod_%28computer_gaming%29.”

2. From 116 Yale L.J. 226, in a footnote: “Between 1965 and 1974, the government of Sweden, a nation of roughly 4 million households, supervised the construction of 1 million housing units (the “Million Programme”), a majority of which were subsidized apartments. See Christopher Caldwell, Islam on the Outskirts of the Welfare State, N.Y. Times Mag., Feb. 5, 2006, at 55, 56; Wikipedia, Million Programme, http://en.wikipedia.org/wiki/Million_Programme (last visited Sept. 1, 2006).”

3. From 41 Ga. L. Rev. 1, in a footnote: “Spyware is malicious software that takes control of a user’s computer for the benefit of a third party and can be used to surreptitiously monitor the user’s online activity. Wikipedia, Spyware, http:// en.wikipedia.org/wiki/Spyware (last visited Aug. 25, 2006).”

4. From 10 Lewis & Clark L. Rev. 673, in a footnote: “For example, after premature and unverifiable claims of cold fusion by Stanley Pons and Martin Fleischmann were discredited, both Pons and Fleischmann were driven from their academic positions. See, e.g., Wikipedia, Stanley Pons, http://en.wikipedia.org/wiki/Stanley_Pons (last visited Apr. 11, 2006) (noting that both Pons and Fleischmann moved to France and accepted jobs for the Toyota Corporation after their cold fusion work was discredited).”

5. From 4 Ohio St. J. Crim. L. 223, in the text: “Ridgway, the most prolific serial killer in American history, pleaded guilty to forty-eight charges of aggravated first degree murder. King County Prosecuting Attorney Norm Maleng then congratulated himself: ‘This agreement was the avenue to the truth. And in the end, the search for the truth is still why we have a criminal justice system.’ [FN]” From the footnote: “See Wikipedia entry on Gary Ridgway, at http:// en.wikipedia.org/wiki/Gary_Ridgway (last visited Mar. 23, 2006).”

6. From 37 Loy. U. Chi. L.J. 753, in a footnote: “Ebert & Roeper gives a “Thumbs Up” (favorable review) or a “Thumbs Down” (unfavorable review). Wikipedia: Ebert & Roeper, http://en.wikipedia.org/wiki/Ebert_&_ Roeper (last visited Feb. 6, 2006).”

7. From 79 S. Cal. L. Rev. 945, defining the term “netizen”: “See Wikipedia, Netizen, http://en.wikipedia.org/wiki/Netizen (last visited May 19, 2006). A Netizen (a portmanteau of Internet and citizen), also known as a cybercitizen, is a person actively involved in online communities for the purpose of giving and receiving viewpoints, furnishing information, fostering the Internet as an intellectual and a social resource, and making choices for self-assembled communities. See id.”

8. From 115 Yale L.J. 1699, in the text: “So perhaps he won’t take offense if I call him a bricoleur, defined by Wikipedia as “a person who creates things from scratch, is creative and resourceful: a person who collects information and things and then puts them together in a way that they were not originally designed to do. [FN]” From the footnote: “Bricolage, in Wikipedia, http://en.wikipedia.org/wiki/Bricolage (last visited Dec. 7, 2005).”

The examples above include several by well-known law professors and a judge. I’m curious which citations readers find appropriate or inappropriate and why.

UPDATE: Mary Dudziak (law, USC) weighs in over at Legal History Blog about Wikipedia’s accuracy in history articles.

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20 Responses

  1. In response to a student editor’s insistence on a citation for something I considered common knowledge, I stubbornly sent back a citation to wikipedia. (I don’t remember exactly the “fact” I needed support for, but it was similar to “there are 52 cards in a standard deck.”) The editors responded that the review had a policy not to cite to Wikipedia. The problem here is not that scholars are citing to Widipedia for authority for scholarly propositions; the problem is that citation norms have evolved to demand citations for undisputed facts that would require hours of trudging through reference materials for an unnecessary citation. Your example of the “thumbs up, thumbs down” Ebert & Roeper cite seems perfect. What would be a truly authoritative cite for that? Should we inter-library loan some book on film criticism or a biography of one of the two to satisfy the need to cite to every sentence?

    Of course, editors will accept a cite to a law review article for statements of fact. So, if I cited to a law review article whose author also stated that there were 52 cards in a deck, that would be fine. (Or a law review article that explained the Ebert/Roper formula.)

  2. Ubertrout says:

    I find #2 troublesome. It deals with a serious and doubtless complex social program, and for authority it cites to a Times Magazine article tangentially on point and Wikipedia. Surely the author could have cited to an official publication or some scholarly work on the project.

    #4 troubles me slightly, but the point made strikes me as not hugely important on the merits. All the others seem fine to me, and point out another area not frequently realized – Wikipedia is excellent for information about technological/social developments that are moving far faster than the academic literature.

  3. Deven Desai says:

    In an article called Wikipedia Founder Discourages Academic Use of His Creation on the Chronicle of Higher Education Web site, Jimmy Wales asserted that students should not use the Web site in “for class projects or serious research.” Fair enough. That view probably resonates with most who look at this question. But Christine’s point about the demand for citation to otherwise common knowledge and so on shows the problem for law review writing. Put differently if one demands a cite for a tech term, is webopedia (a site “dedicated to computer technology) any better than Wikipedia? I would think it is about the same for that purpose. As Wales noted about Wikipedia “‘It is pretty good, but you have to be careful with it,’ he said. ‘It’s good enough knowledge, depending on what your purpose is.'”

  4. Bruce Boyden says:

    Dan, I refuse to consider your question, as I have blacklisted any professor that mentions “Wikipedia” on a blog.

    Oh no! I’ve mentioned Wikipedia on a blog!

    Oh no, I did it again!

  5. (1) is excellent; it directs the reader to a good initial source for further reading.

    (2) is marginal. The Wikipedia citation is probably better than the New York Times article, but if the point is significant, the author probably ought to have found a more detailed source than the rather short Wikipedia article.

    (3) should have been a see generally. Note that the cited Wikipedia page no longer defines spyware in the same way it does; the definition now focuses on surveillance rather than control.

    (4) is bad. The cited article is a stub and does not provide much information. The Physics Web article linked from the Wikipedia page would have been a better citation.

    (5) is odd; I would want to see more context before passing judgment.

    (6) is a good source, but why on earth does this need a footnote?

    (7) plagiarizes from Wikipedia — it needs quotation marks.

    (8) is a perfect citation, given that it is supporting the claim that “Wikipedia says X.” Was it appropriate to use Wikipedia as a source for the definition? Yes: the definition is both accurate and well-phrased.

  6. Eric Goldman says:

    Given the risk that a fact could be from a not-credible source or the product of vandalism, I would be extremely reluctant to cite to Wikipedia for any objective facts unless (a) I knew from other sources that the facts were true, (b) it was difficult to find a better source, and (c) I was being squeezed for a gratuitous citation. This looks exactly like example #6. Thus, I find #2, #4 and #5 particularly worrisome.

    Using Wikipedia for definitions is OK so long as (a) it has internal credibility (i.e., not the obvious product of vandalism), and (b) the the time/date of the citation is clear due to the fact it could change at any moment. Thus, #2, #7 and #8 are generally OK, although they would benefit by expressing saying “as Wikipedia defined the term on X date…”

    #1, as a source for additional material, seems generally OK. Eric.

  7. Jason says:

    A wikipedia article is, to my mind, one of two things:

    (a) well-documented with citations to its own sources; or

    (b) completely unreliable.

    In the former, citations for assertions of fact should be made to the original sources that wikipedia cites. In the latter, of course, no citation should be made.

    To back off the strong stance a tiny bit, I’ll say that a “see generally” to a wikipedia article might be somewhat appropriate sometimes, particularly on things it does well (e.g. geek culture).

    As to the sniping about law journal editors requiring a citation for everything: raise your hand, law professors, if you’re currently serving as the faculty advisor to a journal at your school, or are in some other capacity actively working to change the system (in some other way than writing blog posts and articles!).

    It’s entirely possible that Christine and Deven are active in that manner. But I’d guess that 90% of the complainers in general are not.

  8. Eric and Jason, how, if at all, does it change your assessment of the reliability of a Wikipedia citation if the fact involved has remained stable through the past thousand edits to the page? How, if at all, does it change your assessment if the fact was inserted by an editor who has made hundreds of edits to Wikipedia and whose Talk page is filled with praise from other Wikipedians? How, it at all, does it change your assessment if the fact has been debated for months on the Talk page and the current version reflects the consensus of the twenty Wikipedians who participated?

  9. Jack S. says:

    Citation #8 looks like laziness or ignorance. Bricolage and Bricoleur are common words in the French language and can be cited directly to any edition of the French Robert dictionaries. These are neither slang nor a recent addition.

    As I have been taught you should try and get the primary and/or authoritative source.

  10. Dan and all —

    I actually posted on this topic last year on this blog, confessing that I have cited to Wikipedia.

    “I like Wikipedia. In fact, I like it a lot. In fact, I have gone so far as to do what Eugene Volokh warned against — I’ve actually cited to Wikipedia. In fact, I cited to Wikipedia six times in a recently published law review article.”

    “What Wikipedia Is (and Isn’t)”


    My point was that it should be perfectly fine to cite Wikipedia if both you and your reader know what Wikipedia is and what it isn’t. Once more people understand what Wikipedia is, and have confidence that others understand what it is, the level of panic should subside.

  11. Jason says:

    James: none of those things change my views at all. If they’re such stable facts, written by good wikipedians, then they’re likely easy to verify in other, more permanent places, perhaps even ones that Wikipedia itself has cited as sources.

    My problem with Wikipedia is less that I’m afraid it’s wrong (although I do have that fear) than that it’ll be different from day to day. Of course, this criticism can be applied to anything on the web, and maybe the response is just to say, “Archive the copy you’re citing and note where the archived version can be accessed in the footnote.”

  12. Wikipedia provides a stable URL for every past version of an article. Here, for example, is a version of the Aqua Teen Hunger Force entry from February 3. It is still good practice to archive the version one cites (just as it is good practice to archive every online work cited), but except for a “see generally” backgrounder, it’s better practice to cite a specific revision of a Wikipedia article.

  13. Bruce Boyden says:

    James: It seems to sort of diminish the utility of Wikipedia if, in order to rely on it, you have to bring yourself up to speed on the history and credentials of everyone who’s ever edited the page. I mean, it’s supposed to be a time-saver, not a research project. Wikipedia seems useful to me for two things: quickly looking up answers to questions that I don’t care deeply about; and pointing others to pithy summaries on topics I am already familiar with. As long as an article (or judicial opinion) doesn’t turn on the truth of a particular fact, I don’t see any problem citing Wikipedia for it.

    Greg: Welcome to the blacklist!

  14. Gaell Mainguy says:

    WebCite (webcitation.org) may circumvent the ephemeral citation problem. WebCite is a free tool that archives the content of a webpage to allow

    readers in the future to retrieve quoted web pages as they were at the time of the

    citation. Any page at any time can now be identified, archived, quoted and retrieved as

    a separate document.

    With Webcite at hands to freeze entries, Wikipedia can be used to serve scientific or legal purposes.

  15. Ms. Hurt writes: “The problem here is not that scholars are citing to Widipedia for authority for scholarly propositions; the problem is that citation norms have evolved to demand citations for undisputed facts that would require hours of trudging through reference materials for an unnecessary citation.”

    Amen!! writing is tough enough without the need to accentuate its dreariness. Perhaps an online “Journal of Law and Well-known Facts” could be a repository for such info and an easy source for such needless citations. One could even email them with the facts you need to cite so they could even include them on a timely basis. Any school looking to jack up their citation record should be all over this.

  16. WhippyGoldberg says:

    Jason: “In the former, citations for assertions of fact should be made to the original sources that wikipedia cites. In the latter, of course, no citation should be made.”

    Precisely. Anyone who cites Wikipedia for any reason except to talk about **Wikipedia itself** (but why??) is a total hopeless twit. Anyone who cites Wikipedia is proof that they are a bona fide crackpot.


    Wikipedia itself bars original research, so what on earth do you people think that means?? It obviously means that *NO* primary sources are available on Wikipedia.

    Ergo, it’s very easy to figure out that Wikipedia is *useless* for backing up your research. It’s only purpose for existence at most is as a teensy weensy little lead to **real books**.

  17. WhippyGoldberg says:

    Maryland Conservatarian: “Amen!! writing is tough enough without the need to accentuate its dreariness.”

    If it’s so dreary, please don’t waste everyone’s time doing it. Since your ilk are quoting Wikipedia, your “self-sacrifice” is only damaging society with misinformation. The technical term for people like that who lack diligence in what they do is called “jackass”. If someone is paying you, you are stealing their money and should be fired.

    Ask yourself why you are too jaded to exercise a little free will and examine new career choices for yourself if this is a drudgery. Have you talked to a job counsellor? Have you tried anti-depressants? Have you taken a break to contemplate your direction in life?

    There’s nothing that drives me more up the wall than someone who whines and whines about doing something that they chose to do in the first place. It just doesn’t make sense.

  18. Former Law Review Editor says:

    I agree with the point that many LR editors demand more citations than necessary. I also, however, agree with Whippy. Too many of us whine about finding sources for broad propositions or discrete facts. Really, we are just too lazy get our research assistants to help us out, or too lazy to do the research ourselves. We figure, “We got this far bull sh#ting. How dare anyone stop us now.”

  19. Up to 9 months ago we financially contributed funds to Wikipedia but no more, for we thought that it was a good idea and where its thinking was in unison with our own at that time – using knowledge for the good of humankind. When we as novices tried to place our Swiss charity within Wikipedia we were absolutely savaged by the editors. They in fact blocked our right of reply, which is documented by themselves.

    Thereafter we even sent our registration documents via email to the then executive director of Wikimedia, the holding organization, to prove that our international group was registered as a Swiss charity. He did nothing at all. A few months later he resigned with another top Wikimedia executive, ‘Jimbo’s second in command. The greatest problem with Wikipedia that we now find is that they are highly selective in who should place information and where therefore they will never really have a web-based encyclopaedia that is unbiased and totally factual. It is ultimately at the whims of the few enlightened ones who control what should be a great reference. Unfortunately we now see that it is not.

    For anyone interested further on how Wikipedia editors work, the full account including all emails will be part of our next web newsletter ‘Scientific Discovery’. It will be on-line by the end of July 2007. Overall, it is time we feel that Wikipedia looked internally at itself and that they concluded that they have major problems with the way they treat new entrants. This analysis should especially be directed towards the attitude of their editors, who remove the right of reply and delete super-quick for reasons not based on evidence but only hearsay. By the way also, the Wikipedian Editor Zoe who first blocked us and the initial instigator of all the basic trouble, fell out with ‘Jimbo’ and where she as well left a few months later. Apparently she had made a vendetta against a certain professor according to ‘Jimbo’s’ opinion. Thereafter she took her bat and ball home and has never been seen since. I believe she also threatened the embattled professor at the time – the web link is

    Dr. David Hill

    Chief Executive

    World Innovation Foundation Charity (reg. no. CH- – 11th July 2005)

    Bern, Switzerland