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Using Online Citators: KeyCite, Shepard's, and BCite

Provides an example of a case that has been overruled (negative treatment) on Westlaw

BCite on Bloomberg Law

This is an example of a case that has been reversed (negative history) on Bloomberg Law.  It is Samara Bros., Inc. v. Wal-Mart Stores, Inc., 165 F.3d 120 (2d Cir. 1998).

1. Bloomberg Law presents BCite in a way very similar to KeyCite on Westlaw and Shepard's on Lexis Advance.  History and treatment for a case are found in the box to the right of the case. 

The red indicator means that the case is no longer good law for at least one of the points of law it contains.  You have to focus on the BCite Analysis section to the right.   This shows both history and treatment.

The history is listed under the Direct History section and the treatment is listed under the Case Analysis section.    

The BCite Analysis indicates that Samara Bros. has:

  • Direct history and it cites four (4) cases.
  • Samara Bros. v Wal-Mart Stores, Inc., 165 F.3d 120 (2d Cir. 1998) was reversed and remanded by the United States Supreme Court in  Wal-Mart Stores, Inc. v. Samara Bros., 529 U.S. 205 (2000).  This is the negative direct history.  
  • There are thirty-eight (38) documents that cite Samara Bros. under the Case Analysis section.  It appears that thirty-five (35) are positive and  Samara Bros. is distinguished in three (3) documents.  

 

2. If one clicks the link to Direct History Summary, we will see the history for Samara Bros.  It lists both prior history and subsequent appellate history.  Samara Bros. is a U.S. Court of Appeals case from the Second Circuit from 1998.  

It has prior history:

  • Samara Bros. v Judy-Philippine, Inc., 969 F.Supp. 895 (S.D.N.Y. 1997) – a United States District Court from the Southern District of New York case from 1997.  Our 2d Circuit case affirmed it in part and reversed it in part.

It also has subsequent appellate history:

  • Our 2d Circuit case was granted certiorari from the U.S. Supreme Court in 1999 and that can be found in Wal-Mart, Inc. v. Samara Bros., 528 U.S. 808 (1999),    
  • And finally, our 2d Circuit case was reversed and remanded by the U.S. Supreme Court in 2000 with Wal-Mart, Inc. v. Samara Bros., 529 U.S. 205 (2000).    

Note the BCite tabs on the top.  

3. Under the Case Analysis tab on BCite, we can see treatment for Samara Bros.  It lists 38 different cases that discuss/treat Samara Bros.  in both a positive way and a negative way.  These are completely different cases citing Samara Bros.  

Note the Citation Frequency feature to the left.  That indicates how many times the listed case is cited; however, it is unclear what the quantitative difference is between three and five blue bullets.   

4. Under the Citing Documents tab on BCite, we can see more treatment for Samara Bros.  

This includes:

  • Cases that have cited Samara Bros.
  • Court dockets that have cited Samara Bros. 
  • Law Reports that have cited Samara Bros. 
  • Books & Treatises that have cited Samara Bros.
  • Law Reviews & Journals that have cited Samara Bros.  

 

 

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