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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

Shepard's on Lexis +


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

1. Lexis + presents Shepard's in a way very similar to KeyCite on Westlaw Edge and BCite on Bloomberg Law.  Under the Appellate History link, Samara Bros. has prior history. 

History and treatment for a case are found in the box to the right of the case. On Shepard's on Lexis +, the red stop sign means that the case is no longer good law for at least one of the points of law it contains.

Samara Bros. has PRIOR HISTORY with:

  • 969 F.Supp. 895, a United States District Court case from the Southern District of New York from 1997.  


2. Continuing under the Appellate History link, Samara Bros. also has Subsequent History.  

Samara Bros. also has SUBSEQUENT HISTORY in that: 

  • Cert. was Granted in Part by the Supreme Court at 528 U.S. 808 in October 1999, 
  • Motion granted/denied by the Supreme Court at 528 U.S. 1060 in December 1999, and 
  • It was Reversed by the Supreme Court at 529 U.S. 205 in March 2000. This is why there is a red flag, the case has been REVERSED! 

3. If one clicks the Map button, you can see a graphic representation of the litigation chain of Samara Bros. It includes the prior and subsequent history of Samara Bros.  

This includes the citations to the federal intermediate appellate court opinion, as well as the citations to the United States Supreme Court opinions related to Samara Bros.  

4. Under the Citing Decisions link, there is treatment information for Samara Bros.  The Citing Decisions link discusses how Samara Bros. has been treated by different courts in different cases.    

Samara Bros. has been cited in 46 cases from different jurisdictions (federal and state courts).

5. Under the Other Citing Source link, there is more treatment for Samara Bros.  The Other Citing Source link discusses how Samara Bros. has been treated/cited by different secondary sources.      

The Other Citing Source link discusses how Samara Bros. has been treated/cited by different secondary sources.  Samara Bros. has been cited in 113 secondary sources cases including:

  • Annotated Statutory Codes
  • Law Review Articles
  • Treatises
  • Court Documents

6. Continuing in Other Citiing Sources, one can narrow the various types of secondary sources.  

For this, we have limited my results to just law review articles that have cited Samara Bros.  This retrieved 51 law review articles.   

7. One can even further narrow results by a doing a keyword search.

For this, we have limited my results by using the search term “Internet.” This retrieved 24 results.





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