What does a negative treatment in a citator indicate?

• A. The case has been criticized or overruled.
• B. The case is still good law.
• C. The case has never been cited.
• D. The case is outdated.

Answer: (A)

Negative treatment in a citator signals that later courts or authorities have treated the case unfavorably—often by criticizing it or overruling it. This shows the case may not be good law for the issue at hand, so you should check the citing opinions to see exactly what was undermined and whether any part of the decision remains valid. It wouldn’t mean the case is still good law (that would be positive or neutral treatment), nor that it was never cited, and it isn’t simply a matter of being outdated.