Let "YYYY" represent a variable for a given year, what does "through YYYY Leg Sess" at the end of a legal citation mean or signify?

Background and Due Diligence

In various legal documents, such as this one, there are citations that contain "Leg Sess" which I'm guessing is short for "Legislative Session" or "Legislature Session" but aside from probably being wrong, what I'm hoping to understand is what it means and what impact it has when it's used as a Universal Citation as reference on Justia such as here and here referenced below:

Universal Citation: CA Com Code § 14103 through (2015) Leg Sess

In reading the Code being cited (14103) there are plenty of dates being mentioned but none that seem to correlate with 2015 so I'm having trouble understanding if it might mean something significant to its usage whereby, for example, it doesn't apply after 2015 or if another statute is being inferred to take its place.

Universal Citation: CA Civ Code § 1738 (through 2012 Leg Sess)

In reading the Civil Code mentioned above, it's noted that the parenthesis encloses the entire phrase "through 2012 Leg Sess" as opposed to previously where it was only the (assumed to be year) "2015" that was in parenthesis. Whereas in this case, it was amended in 1994 and has an effective date of January 1, 1995 so I'm uncertain of what the 2021 is supposed to reference when included in the citation.

Any attempt to search the meaning on Google results in pages and pages of other documents using the same citation and I had trouble finding a page that might simply explain what is meant by "Leg. Sess."

The Problem at Hand

The question originally being asked is to determine whether or not using any particular code cited in this way would be erroneous when attempting to present what code would be violated in present day.

  • 1
    laws get updated. This is telling you how up to date the info is.
    – Tiger Guy
    Commented Dec 1, 2022 at 6:22
  • As in, it was the last time that particular law was updated? So as far as whether or not it applies by today's standard, I would have to just search the specific law to see if it's been changed and would thus result in a different citation/reference that either won't include it or will include it with a more recent year?
    – Doedigo
    Commented Dec 1, 2022 at 7:15
  • 1
    @Doedigo more often, it's when the text referencing the law was written, if the law then was current. It is a caveat in case the law did change in the interim.
    – Trish
    Commented Dec 1, 2022 at 8:19

1 Answer 1


It means the entire code compilation has been updated to include all legislative revisions to the code that occurred in the XXXX legislative session (and obviously earlier ones too).

Of course, not every section of the code is amended every legislative session, but the compilation will still report that it is accurate through to the end of XXXX legislative session.

This method of reporting currency isn't a good match for online compilations or compilations that receive updates multiple times per year, so you may see variants, like "through 2012 portion of 2011-2012 Reg. Sess." (however the publisher itself reports its currency information).

The Bluebook citation standard had traditionally required this currency information to be cited for all statutes, but in the latest version, that requirement has essentially been removed for federal statutes.

What Justia is calling a "Universal Citation" is probably better called a "media-neutral" citation, following the format of the AALL Universal Citation Guide. However, it's a bit of a misnomer because no entity has a monopoly on citation style, although the Bluebook has a big influence. Justia even mentions, "this universal citation is not necessarily the official citation, the latter which should be used when citing to primary and secondary legal materials in court filings, scholarly publications, etc."

  • 1
    Ah okay, so in the case of what justia refers to as a "Universal Citation" it's merely included as a reference to the last time that particular code had been 'updated' sort of speak?
    – Doedigo
    Commented Dec 1, 2022 at 15:22

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