This paper analyzes the accuracy with which descriptions of subsequent negative treatment are applied by an online citator system that employs a hierarchical controlled vocabulary -- Shepard's Citations -- as opposed to one that does not -- KeyCite. After a contextual review of the citator's history, a framework for assessment is proposed and employed to test the hypothesis that a citator employing a hierarchical controlled vocabulary would produce more accurate descriptions. The study's results suggest that a system making use of a hierarchical controlled vocabulary does apply descriptions of subsequent negative treatment in a marginally more accurate way. A discussion of the citator's place in legal research follows, including the suggestion that legal research instructors and researchers themselves, namely lawyers, should reconceptualize the role citators occupy in the legal research process.