I first used Google Scholar when it appeared on the web more than 20 years ago, then largely forgot about it. I recently rediscovered it for a practical reason: I needed an efficient way to verify court citations provided by ChatGPT and Gemini.
As I discussed in my prior article on using LargeLanguage Models (“LLMs”) for legal research, LLMs can be extremely useful for identifying issues, analyzing arguments, developing counterarguments, and organizing legal research. But they are not trustworthy sources for legal citations. Every citation must be verified. Google Scholar is remarkably useful for that purpose.
Google Scholar provides broad access to federal and state court decisions. You can search generally, narrow the search to particular courts or states, or search by keywords. For many ordinary legal research tasks, it is fast, easy to use, and powerful.
It also has important limitations. Google Scholar does not contain state trial court decisions, pre-1950 state cases, or pre-1923 non-U.S. Supreme Court cases. Its posting lag generally ranges from a couple of days for federal cases to about a month for state court decisions.
Hyperlinked Case Citations
One major advantage is simple: citations within a case are hyperlinked. If an opinion cites another case, one click takes you to the cited decision. That decision, in turn, contains links to the cases it cites. A lawyer can therefore move quickly through a line of authority without repeatedly returning to a search screen and starting over. That feature alone makes Google Scholar useful. But its best feature is “How Cited.”
How Cited
When you open a case in Google Scholar, the “How Cited” tab appears in the upper-left corner. Click it, and Google Scholar displays cases in its database that cite the case you are reviewing. More important, it provides excerpts showing how those later courts discussed the case.
That additional context makes the feature exceptionally useful. Instead of seeing only a case name or a cryptic one-line description, you see a short excerpt showing how the later court used the authority. That often allows you to determine quickly whether the citing case is relevant before opening and reading the full opinion.
For example, I used New York Times Co. v. Sullivan, 376 U.S. 254 (1964), to illustrate the process. The basic case page displays the opinion. The “How Cited” page then displays later cases citing Sullivan, together with excerpts showing how those courts discussed the decision.That is precisely the information a lawyer needs when determining whether a case remains useful and how later courts have treated it.
No Substitute for Legal Judgment
Google Scholar is not a substitute for professional judgment, and lawyers should not blindly treat it as a formal citator.
You still must read the later cases, evaluate the context, and determine whether an authority remains valid precedent and useful for the proposition at issue. Google Scholar does not contain every case, and it does not provide the editorial commentary available through commercial legal research services. But those limitations do not diminish its value as a practical research tool.
Google Scholar also identifies articles and other online materials that mention a case. You can create alerts, move quickly from one authority to another, and verify LLM- generated citations without immediately resorting to an expensive commercial legal research platform. For many research tasks, speed and usability are the point.
My Current Research Process
The modern legal research process has changed. My current approach is:
1. Use ChatGPT or Gemini to identify legal issues, arguments, counterarguments, and potential authorities.
2. Use Google Scholar to verify cases, read opinions, and determine how later courts have cited them.
3. Use other free online resources to double-check statutes, regulations, cases, and secondary materials.
4. Apply critical lawyer judgment before relying on anything.
Other useful free resources include Justia, CourtListener, Cornell Law Information Institute, FindLaw, and Caselaw Access Project. Each has strengths and limitations. Taken together with Google Scholar, however, they can satisfy a substantial portion of ordinary legal research needs without resorting to expensive and, in many respects, functionally outdated traditional research platforms.
Do Not Trust — Verify
This critical rule remains the same and applies to LLMs, free online research tools, and, frankly, expensive research tools as well. For me, the combination of LLM-assisted research and Google Scholar verification has been faster, more flexible, and more useful than the traditional legal research model. It is not perfect. But it is free, easy to use, and powerful.For lawyers who want fast access to case law, hyperlinks to cited authorities, and an efficient way to see how later courts have discussed a decision, Google Scholar is a hidden gem.