“…Some citations to precedent are incidental, others are negative, and some are deferential. Fowler et al (); Fowler and Jeon (), and Patty, Penn, and Schnakenberg () focus on a citation's networked position and analyze all types of citations, positive, negative, and neutral, together. Alternatively, Hansford and Spriggs () consider the nature of citations when measuring precedent, at the Supreme Court level exclusively.…”