Looking at citations from 2001 on, and controlling for different numbers of notes in each journal by dividing by the count of all published notes from 1995 on:
Harvard: 358 citations.
Yale: 106, with 78% of the number of notes in Harvard.
Stanford: 48, with 40% of the number of notes in Harvard.
I count here only articles denominated as "Note" (not "Recent Case" or some such), and citations that refer to them as "Note." There are a few false positives and surely some false negatives in each query, but I have no reason to think they'd throw the results off.