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Case Finding and Advanced Searching Strategies

What Are Notes of or to Decisions?

If the issue you are researching involves a statute, regulation, or court rule, an efficient strategy for finding relevant cases involves checking the Notes of Decisions (Westlaw) and Notes to Decisions (Lexis) for that statute, regulation, or court rule. Notes of/to Decisions are like a highlights reel of cases applying or interpreting the statute; they are example cases selected by the editors of Westlaw or Lexis that address certain topics. Because the cases included in the Notes of Decisions and Case Notes are selected by editors, it is a good idea to check both Westlaw and Lexis - they'll often have selected different cases, or included cases on a topic that the other left out. 

Notes of/to Decisions are selected from among the Citing References and Citing Decisions. Citing References and Citing Decisions consist of all cases that cite to a statute, regulation, or court rule. Notes of/to Decisions are thus a subset of the Citing References / Citing Decisions. 

Note: For some statutes, Lexis refers to "Case Notes" instead of "Notes to Decisions", so if you see both of these terms when conducting research on Lexis, know that they are synonymous! 

Notes of Decisions (Westlaw)

After you find the statute, regulation, or court rule on Westlaw, click on the tab for "Notes of Decisions" near the top of the screen. 

Screenshot of Westlaw's page for a statute showing the Notes of Decisions tab above the statute's text

The Notes of Decisions list cases relevant for interpreting or construing the statute, regulation, or court rule, arranged by topic. You can scroll through the list of topics in the left-hand sidebar, as well as filter the cases displayed by date, jurisdiction, and key number. Each case contains a one-sentence description or summary to demonstrate why the case is relevant for that topic. You may see some of the same cases filed under different topics throughout the Notes of Decisions. 

Screenshot of a statute's Notes of Decisions page on Westlaw, showing the Table of Contents with topics on the left and the list of cases by topic on the right

 

Notes to Decisions (Lexis)

Lexis provides Notes to Decisions (sometimes also referred to as Case Notes) for statutes, regulations, and court rules. You can view the Notes to Decisions by scrolling down past the text of the law, regulation, or court rule and looking within the "Annotations" section. Depending on the statute, you might have to scroll through some "Notes" in the Annotations section too; Notes to Decisions will appear below Notes (confusing, we know). 

Screenshot of Lexis's Notes to Decisions for a statute, showing the list of topics and beginning of the list of cases arranged by topic

The topics selected by the editors on Lexis for Notes to Decisions differ from the topics selected by the editors on Westlaw for Notes of Decisions. The selection of example cases for inclusion in the Notes to Decisions may also differ, so it can help to check both.