Feature
Democracy
in the Dark:
Public Access
Restrictions from Westlaw and LexisNexis
by Melissa Barr • Legal Resources Specialist • Cuyahoga
County Public Library
"Democracies
die behind closed doors....When government begins closing
doors, it selectively controls information rightfully
belonging to the people. Selective information is misinformation." So
spoke Judge Damon Keith in Detroit Free Press, et
al. v. Ashcroft. Judge Keith was discussing closed
immigration hearings in the wake of 9/11. He might
have been talking about the public's lack of access
to legal information databases, especially case law
databases. Although many courts now publish case law
on the Internet for free, thousands of older cases
are not available to those who cannot pay. Hundreds
of public libraries across the country provide online
access to their patrons in an attempt to bridge the
digital divide, covering all areas of information need.
Yet often these public libraries are not allowed to
offer access — free or fee — to legal subscription
databases maintained by the two largest legal vendors
in the U.S. And those same vendors also constitute
the largest publishers of legal materials in print.
Amidst a growing wealth of free, reliable information
on the Internet, there is a poverty of access to the
decisions and opinions of the courts that protect our
liberties.
Response From LexisNexis
and West
LexisNexis in the Library Market
Libraries play a vital role in a democratic
society, and LexisNexis appreciates the service
they provide, along with the librarians who
manage and staff them.
Most libraries are struggling more than they
have historically to meet the needs of their
patrons with a wider array of electronic information
technologies in addition to the traditional
hard-copy versions of publications. Public
libraries are no different. At the same time,
the World Wide Web facilitates the direct,
free access to more and more information from
the courts, legislatures, and university Web
sites, raising awareness of the vast amount
of information available. This situation is
an irony, but certainly not a conspiracy by
the online publishing industry, as the author
seeks to imply.
Remembering that LexisNexis is a business-to-business
enterprise, the company tries hard to accommodate
its customers in the library market with flexible,
discounted plans. LexisNexis sales reps discussed
several options with the writer, Melissa Barr,
although none of the plans would allow her
to do what she wanted to do — give unlimited,
unmediated access in multiple locations to
the LexisNexis legal information service at
an unrealistic price.
LexisNexis provides numerous products and
services that allow public library patrons
access to critical information at a reasonable
cost to libraries. The first, of course, is
our subscription-based online services for
news, business, and legal information. These
services are available to public libraries
on a mediated basis, that is, a librarian will
perform a patron's search for them at no charge
to the patron. If service were not mediated,
then LexisNexis would have no business left
from subscribing attorneys. If the library
doesn't have the budget to pay for a subscription,
then we offer lexisONE, designed for small-practice
attorneys but also useful to non-attorneys.
lexisONE combines 5 years of free case law,
thousands of free legal forms, and an Internet
Legal Guide with links to more than 20,000
law-related Web sites. We only ask that the
user register on the site, and it costs nothing
to do so.
LexisNexis by Credit Card
[http://web.lexis.com/
xchange/ccsubs/cc_prods.asp]
is
specifically designed for non-subscribing members
of the general public who want to search either
business or legal information on our flagship
products, nexis.com or lexis.com. Case law
is available for searching regardless of how
long ago the cases were decided. There is no
charge to search or review a list of relevant
documents found, and charges are as low as
$9 per document to view a case, code, or statute,
or $75 a week to conduct a research project
in the news and business libraries.
LexisNexis currently is trying to launch
another program that would address some of
Ms. Barr's concerns. We are seeking libraries
with up-to-date PC technology to pilot the
LexisNexis legal service using an authentication
scheme that doesn't require librarian involvement
in the searching. To date, libraries have had
a security concern with allowing users to directly
log onto a PC using the library's subscription
ID and password. There has been no way to prevent
the user from running up charges on the library's
account using a remote terminal. This is a
security issue, not a denial-of-access issue.
Lastly, LexisNexis is a tireless supporter
of the Special Libraries Association's educational
efforts. It also has donated millions of dollars
of direct contributions or in-kind services
to support pro bono legal aid programs run
by local bar and state associations. For instance,
LexisNexis and the National Association of
Bar Executives (NABE) recently honored outstanding
public service programs of five bar associations
by presenting each with $25,000 in research
credits. Pro bono support offers the highest
value for patrons in the greatest need.
Hopefully this brief description of the company's
efforts will reassure public librarians that
LexisNexis is concerned about and willing to
work with them to tailor and integrate our
information content and productivity tools
into their environments.
West: Unprecedented Access to Legal
Information
Access to the nation's laws is critical to
the success of our democracy. Thanks to the
Web, legal information is readily accessible
by more people today than at any other time
in history.
Facilitating the flow of information from
courts and lawmakers is a vibrant tradition
in which we at West are proud to have played
a key role. More than 125 years ago, founder
and namesake John B. West created the publication
and editorial processes that resulted in the
National Reporter System. His forethought and
insight provided the groundwork for every law
firm and county law library in the country
to offer dependable, on-time access to these
materials.
Today, West's attorney-editors read more
than 200,000 judicial opinions annually, working
with the courts to make more than 100,000 corrections
to these rulings. Our unique editorial process
delivers powerful editorial enhancements — synopses,
headnotes, and classification to the West Key
Number System — that help legal researchers
find and analyze on-point information faster
and easier. Moreover, this process guarantees
the accuracy and integrity of these critical
legal information resources.
In addition to using the bound volumes in
their local or firm law library, thousands
of legal professionals now access the National
Reporter System, as well as statutes, regulations,
and business news and information via Westlaw.
Services such as Westlaw provide innovative
research tools that are specifically designed
for use by legal professionals. These professionals
balance the cost of using services such as
Westlaw with the time they save and the comfort
they gain from knowing they are using the most
authoritative, current, and accurate information.
West employs over 7,000 full-time legal,
software, and business professionals dedicated
to providing the information and technology
that makes Westlaw possible. Add to that one
of the world's largest and most complex technology
infrastructures and around-the-clock customer
service and research support (including technical
and legal specialists), and you begin to understand
the resources West commits to meeting the daily
needs of the legal professional.
Of course, the Web encourages healthy competition
from new businesses as well as from the various
governmental organizations. Users are benefiting
from a continuing, rapid innovation of services
and a broad diversity of offerings.
West is vigorously and creatively responding
to the new world enabled by the Web. For example,
in January 2001, West acquired FindLaw [www.findlaw.com],
the leading legal information portal on the
Web. By providing a wealth of legal information,
related analyses, and legal data without charge,
FindLaw attracts businesses and individuals
seeking legal advice and directs them to appropriate
legal professionals. Recent statistics indicate
that FindLaw traffic is five times that of
its nearest competitors as measured by its
user base.
West remains dedicated to its long standing-tradition
of service to the bench and bar. Through FindLaw,
West has expanded this commitment to the larger
community.
— Mike Wilens, President,
West |
Two multinational corporations control print and electronic
legal research materials used by courts and law firms
in the U.S. Canadian conglomerate Thomson Inc. owns
Minnesota-based West Group Inc., developer of the Westlaw
legal database. Anglo-Dutch conglomerate Reed Elsevier
Inc. owns Ohio-based LexisNexis1 Inc.,
which owns the electronic database by the same name.
For over a decade these companies have been on a buying
spree. Thomson and West Group acquired nearly 20 legal
publishers in North America, the free FindLaw database,
and the online legal directory, Lawoffice.com. Reed
Elsevier and LexisNexis acquired nine legal publishers
in North America and at least three electronic databases2.
Wolters Kluwer, another Dutch corporation, acquired
several legal and business publishers in the U.S.,
but runs a distant third in this publisher's sweepstakes.
Thomson and Reed Elsevier have nearly cornered the
market for legal research materials. Then-president
of the American Association of Law Libraries, Robert
Oakley, expressed concern in an August 2000 Washington
Post interview. "You've really got only two publishers
to choose from, and you can't go beyond that. Together
they exercise almost total control over the marketplace."3 Through
their numerous subsidiaries, the two companies publish
print versions of federal and state court cases, federal
statutes and codes, state statutes and codes, and supplementary
legal materials, including dictionaries, encyclopedias,
law firm and attorney directories, state and federal
handbooks, forms books, and manuals. Many of these
publications are recognized by courts as respected,
authoritative sources for legal opinions, definitions,
and interpretations; some have even become the "official" publications
for statutes, codes, and case law.
On October 30, 2002, LexisNexis announced that it
had signed a 7-year contract with the State of Virginia4 to
maintain the state statute Web site. This is a convenient
contract, since LexisNexis owns Michie Company and
Michie has published the Code of Virginia for so long
that it was nicknamed the Michie Code. LexisNexis has
contracts to maintain free statute sites for the states
of Delaware, Mississippi, New Mexico, Tennessee, and
Vermont. The company also announced its merger with
Anderson Publishing Company5,
a Cincinnati-based legal publisher that maintains the
official, free Web site for the Ohio Revised Code,
Ohio Administrative Code, and Ohio Court Rules. Anderson
publishes the print versions of the Ohio codes and
rules, as well as handbooks and manuals for Ohio and
15 other states.
The contract for the District of Columbia code is
currently held by Westlaw. Published by Michie for
many years, in 1999 publication of the code was in
limbo. LexisNexis acquired the contract when it acquired
Michie in 1994. The city put the contract out to bid
in 1999. West Group was awarded the contract a month
after the old contract expired. Because of the delay,
LexisNexis argued to have the contract rebid, but refused
to give up the subscriber list for the code. Without
the list, West didn't want the contract. LexisNexis
offered to publish the code in exchange for temporary
copyright access to some materials. City officials
were outraged that LexisNexis wanted to "own" the law6.
In January 2001 the contract was awarded to West7.
Many court Web sites provide access to current case
law, but sites generally go back only a few years and
documents may require downloading onto a hard drive
or a disk, something not always possible on public
library Internet terminals. I surveyed each state's
case law Web site via FindLaw [http://www.findlaw.com/11stategov/] and
found that most state databases don't include opinions
prior to 1995. The oldest database is Oklahoma, with
cases from 1919 on. California starts in 1934, and
Hawaii in 1989. Six states include opinions from 1990
to 1994. A seventh state, Ohio, has opinions from 1990
on for the Eighth District Court of Appeals, but most
Ohio appellate courts start in 1997. The Ohio Supreme
Court site directs users to the FindLaw Web site for
older cases, as the court only archives current cases.
Although the FindLaw site archives Ohio Supreme Court
material back to 1997, for appellate court cases it
links to the official appellate court Web site. Cases
cannot be viewed on the screen as users must download
documents to a disk or a drive. I work at the eighth
busiest library in the country, Cuyahoga County Public
Library in Ohio. The library doesn't have download
capabilities on its public or staff terminals. Cases
on the Ohio court Web site are not accessible for anyone
using a public terminal. The digital divide is still
there.
Numerous gateway sites supply links to state and
federal court sites. The once-independent FindLaw site
is now owned by West Group. FindLaw has U.S. Supreme
Court cases back to 1896. Circuit court of appeals
cases vary by circuit, but most include cases from
either 1994 or 1995 on. The district court section
simply links to each court's site, so coverage varies.
Quite a few universities have excellent legal gateways
available free on the Internet, providing links to
federal and state constitutions, statutes, codes, and
cases. The Cornell University Legal Information Institute
site [http://www.law.cornell.edu.] is
my personal favorite, in part because I've memorized
the URL. A few years ago, I searched every state's
statutes for laws on the privacy of patron records.
The Cornell Web site was invaluable in locating the
state statutes, but each state database had to be searched
one at a time, and the information was indexed differently
in each state. Some searches took mere seconds, while
others required repeated attempts and literally took
days. Louisiana and Pennsylvania were the only states
without their statutes available in full for free on
the Internet. Currently, Louisiana is up and running,
but Pennsylvania is still working on it.
No Public Libraries Need Apply
Using one of the legal vendors would
have been much faster. Cuyahoga County Public Library
had a subscription to Westlaw and several West CD-ROMs
at that time. I wasn't willing to spend the library's
money at the rate of $14 per minute (plus print costs)
for Westlaw, when the information was available free.
Our Westlaw subscription was mainly used to pull up
business information or cases not available on the
Ohio and federal CD-ROMs. Patrons were not allowed
to use the Westlaw subscription. We also had a subscription
to Ohio forms on LawDesk. The content was great, but
patrons found it difficult to use. After much persuasion,
West allowed the library to network the Ohio CD-ROM
material to public terminals at four of our 24 libraries.
When our contract expired at the end of 2001, we
attempted to negotiate a flat-rate Westlaw contract
for all of the materials from the CD-ROMs, plus some
other databases. We hoped to make legal databases available
to the public at all of our branches, although with
a limited number of concurrent users. Neither Westlaw
nor LexisNexis was ready to offer such a contract to
a public library. LexisNexis' Academic Universe product
includes a legal database, but it is marketed only
to schools and colleges. Public libraries cannot subscribe
to Academic Universe. LexisNexis products available
to public libraries don't have the legal database.
Westlaw does not have any similar products.
Bear in mind that West Group and LexisNexis, the
two largest vendors of online legal information in
the country, do not offer their online legal
products to public libraries for patrons to use. A
quick check of the American Library Directory lists
16,598 public libraries in the U.S. There are 416 law
libraries listed under "Government Libraries" and 1,045
law libraries listed under "Special Libraries." Some
of those government and special libraries and all of
the public libraries are open to the public, serving
millions of patrons each year. For many Americans,
the public library is their only access to the Internet.
LexisNexis has a pay-as-you-use product called LexisNexis
Courtlink. Billed as "the online link to our nation's
courts," the product describes who needs to access
the courts. In the "Who we serve" section of the site,
it states:
Law firms, banks, insurance companies, corporations,
government agencies, investigative firms, the media
and other businesses rely upon court records to make
informed decisions and avoid costly mistakes.... Courts
who use CourtLink eAccess also benefit through increased
operating efficiencies, improved customer service and
a better-informed public" [http://www.courtlink.com/who/who.html].
The "other businesses" include information providers:
Legal information providers can offer private label
access to federal and civil court cases. Investment
services can supply potential investors with access
to recent court cases involving any public company.
News sites are able to list recently filed cases of
interest to their audience — those involving local
community issues, local companies, hot topics, and
more [http://www.courlink.com/who/providers.html].
The "LexisNexis CourtLink for You" section is subtitled "Because
all kinds of people need access to court records" [http://www.courtlink.com/who/index.html].
The section continues: "Attorneys aren't the only ones
who need access to the nation's courts. Individuals
in all types of professions draw on court records to
do their jobs" [http://www.courtlink.com/who/others/others.html].
In a later paragraph, it states:
A traditional search can cost up to $300 and take
several hours or even days to complete. With CourtLink
eAccess the average search costs less than $25, takes
less than 5 minutes, and produces more complete, up-to-date
results.... LexisNexis Courtlink is the leading provider
of online access to and from the nation's courts, with
more than 200 million records in over 4,000 federal,
state, and local courts.
Even in its own advertising LexisNexis acknowledges
that "all kinds of people need access to court records."
Alternatives?
The two main fee-based competitors available to public
libraries are Loislaw8 and
Versuslaw9. Another competitor,
Quicklaw, was acquired by LexisNexis' Canadian counterpart,
LexisNexis Butterworths Canada, in July 2002. The subscription
services offer one-stop shopping for case opinions,
statutes, and administrative regulations, with one
search interface, rather than data scattered across
dozens of Web sites with sometimes questionable URLs
and search engines.
After checking out these vendors, in 2002, we signed
a contract with Loislaw [http://www.loislaw.com],
as its product proved a good match for our library's
needs. According to our sales representative, Travis
Stephens, Loislaw was already available at over 50
public libraries across the country. We networked the
subscription to all 28 branches of our library system,
using IP authentication to eliminate the need for passwords
or user IDs. The subscription allows six concurrent
users to search the entire Loislaw database, but only
Ohio and federal materials are available in full text.
Staff and patrons enjoy the easy access and depth of
coverage.
Loislaw offers subscriptions to public libraries
and anyone else who wishes to buy them. Versuslaw is
available to anyone willing to pay from $8.95 per month
up to $34.95 per month for a subscription10.
The two giants do let the paying public use
their databases. Westlaw and LexisNexis take credit
cards on a pay-as-you-go basis, charging flat rates
for documents, with search and print charges included.
West documents cost $12 each; KeyCite checking costs
$4.25 for each result11.
You get charged when you click on the link to display
the document or KeyCite result. LexisNexis charges
only $9 per document, and the charges apply when a
document is viewed. An accidental click can result
in big credit-card bills.
LexisNexis offers the "free" LexisOne service, intended
for small law firms and sole practitioners. It requires
users to register to search the database. The U.S.
Supreme Court case database goes back to 1790. Only
the last 5 years of U.S. Circuit court cases and state
court cases are available for free. U.S. District Court
cases are not available for free on LexisOne. LexisOne
allows users to purchase cases otherwise unavailable
(i.e., not free) cases.
The Lonely Litigant: A Case in Point
In 1990, the American Bar Association conducted a
study of pro se (self-represented) litigants.
Although limited to the Domestic Relations Court in
Maricopa County (Phoenix), Arizona, the numbers were
significant enough for the bar to take notice. "Research
showed that at least one party was self-represented
in more than 88 percent of the divorce cases, and in
52 percent of them, both parties were on their own."12 Maricopa
County courts are among a handful of courts that have
set up self-help programs for pro se litigants
or offered attorney training on unbundling legal services,
so an attorney can handle one or two aspects of a case
for a pro se client. The ABA's Standing Committee
on the Delivery of Legal Services offers help on its
Web site [http://www.abanet.org/legalservices/delivery/delunbund.html].
Unfortunately, as with many legal research sites, the
information is geared for attorneys, not pro se litigants
or ordinary citizens. The site has a list of articles,
books, court cases, and so on about unbundling legal
services and dealing with pro se litigants.
Links to four self-service centers are buried at the
bottom of the Web page.
The legal field is more maze than field with overlapping
systems of courts, statutes, codes, regulations, case
opinions, and legal citations. Legal jargon — partly
in Latin, partly in English, but mostly in legalese — adds
to the confusion. Laws are written in language broad
enough to be applied to many factual situations, yet
specific enough to be applied to a recognizable legal
principle or situation. If the law says you must be
18 years of age to vote, then you cannot vote if you
are 17 years, 11 months and 29 days old on Election
Day. Missing it by that much doesn't cut it.
However, many laws are less specific and may be open
to interpretation. That's when the courts get busy.
If politicians pass a "bad" law — such as one
that is vaguely worded or cannot be enforced without
violating our civil rights — the courts can overturn
the law and in essence tell the politicians to try
again. If local governments or law enforcement applies
the law incorrectly, the courts can clarify how the
law should be enforced.
The courts provide us with case opinions or legal
opinions collectively known as case law, or cases.
(An ongoing lawsuit may also be called a case.) The
opinion describes the facts of the case, the law or
laws applied to it, and how the court decided to apply
the law(s) to the facts. In the state court system,
trial courts are at the bottom of the pyramid, followed
by appellate and supreme courts, or their equivalents.
Usually, only appellate and supreme courts generate
opinions. In the federal court system, case opinions
are generated by district courts (the trial courts),
circuit courts of appeal, and the U.S. Supreme Court.
The opinions are printed in a set of books known as
an official "reporter" and become part of American
case law. Other courts may use these opinions in deciding
new cases with similar facts and laws. Lower-level
courts follow decisions made by the courts above them,
with the U.S. Supreme Court at the top of the legal
pyramid.
Why should ordinary citizens be interested in opinions
written by judges decades or even centuries ago? After
all, we can read the laws ourselves, since most public
libraries buy copies of the local ordinances and may
also have state and federal codes. And it's available
free on the Internet. Do we really need judicial opinions?
Yes, we do, because even century-old case law can still
be "good law." A U.S. Supreme Court case from 1888
was instrumental in overturning an Internet copyright
case covered in the February 2002 edition of Searcher.
Carol Ebbinghouse13 discussed
the then-unresolved copyright infringement case involving
Peter Veeck, his Web site, and the basic building codes
of two small Texas towns.
Mr. Veeck purchased an electronic (CD-ROM) copy of
local building codes and copied them onto his free
Web site for anyone to use. When the author and purported
copyright holder of the codes, Southern Building Code
Congress Inc., ordered Mr. Veeck to remove the codes,
he sued them, claiming the codes were in the public
domain because they had been adopted in full by the
local communities as official building codes. Mr. Veeck
lost at the district and circuit court levels but appealed
to the Fifth Circuit Court of Appeals for a hearing en
banc a hearing by all of the judges on the
court, rather than the smaller panel of judges that
had ruled against him. On June 7, 2002, in an 8 to
6 split, the Court ruled in Mr. Veeck's favor. In the
court opinion, Judge Edith Jones quoted from a 115-year-old
decision by the U.S. Supreme Court, Banks v. Manchester14,
that exempted court opinions from copyright law as
a matter of public policy. FindLaw's
[http://www.findlaw.com/casecode/supreme.html] free
database of Supreme Court opinions only goes back to 1896,
but fortunately Mr. Veeck had posted a copy of the case on
his Web site [http://regionalweb.texoma.net/cr/banks.html].
The Banks case is worth a second look. The
State of Ohio awarded a contract to publish Ohio Supreme
Court opinions and hired E.L. DeWitt to prepare the
opinions for printing. Mr. DeWitt copyrighted the opinions
on behalf of the State of Ohio. When another publisher
reprinted some of the opinions, it was sued for copyright
infringement. The Banks court stated that the
actual case syllabus, statement, and opinion were the
work product of the judges and neither the State, the
judges, nor anyone else could copyright the court's
work product. "The whole work done by the judges constitutes
the authentic exposition and interpretation of the
law, which, binding every citizen, is free for publication
to all, whether it is a declaration of unwritten law,
or an interpretation of a constitution or a statute."15
Without access to 19th-century case law, the Fifth
Circuit Court might not have found a precedent to overturn
its earlier decision in Veeck. In explaining
why a particular law can or cannot be applied to a
particular case, courts establish a guide for politicians,
law enforcement personnel, and ordinary citizens in
how to write, enforce, and follow the law. Ignorance
of the law is no excuse for not following it. However,
figuring out what law is applicable to your situation
and finding print or electronic versions of cases to
support your position can be costly in both time and
money.
Still the People's Law
Westlaw and LexisNexis add copyrighted editorial
enhancements to their versions of the court opinions
to aid attorneys and judges in interpreting major and
minor points of the case and to locate similar cases.
Those enhancements are copyrighted, and rightly so,
being original work product added to the material.
Wherever the two firms couldn't corner the copyrights,
they bought the competition.
However, the courts and the court's words belong
to us. In more ways than one, the American people have
already paid for the case law produced by our courts.
Commercial vendors must not be allowed to highjack
our law or dictate who may have access to it. By refusing
to allow public libraries to purchase electronic subscriptions
that can serve their patrons, Westlaw and LexisNexis
are closing the door on information.
Footnotes
1 In recent year LexisNexis
played around with variations on the company name,
even shortening it to Lexis, but recently reverted
back to LexisNexis without the original hyphen.
2 Based on information
reported in the "Legal Publishers List" maintained
by the American Association of Law Libraries, Committee
on Relations with Information Vendors (CRIV). Data
was as of 10/25/02, with the sale of Anderson Publishing
Company to LexisNexis pending shareholder approval.
3 Sewell Chan, "District
Finds Itself Without a Legal Clue," The Washington
Post, 25 August 2000, section B, p. 1. (http://washingtonpost.com/wp-dyn/articles/A21251-2000Aug25.html)
4 LexisNexis news
release dated October 30, 2002, "LexisNexis Signs
Seven-Year Contract, Named Official Publisher of
Virginia Code." http://www.lexisnexis.com/about/releases/0548.asp.
5 LexisNexis news
release dated October 9, 2002, "LexisNexis, Anderson
Publishing Company to Merge."
http://www.lexisnexis.com/about/releases/0543.asp.
6 Chan, "District
Finds Itself Without a Legal Clue," section B, p.
1.
7 Chan, "Update:
On the News," The Washington Post, 5 February 2001,
Section B, p. 2.
8 Loislaw is currently
owned by New York based Aspen Publishers, Inc., a subsidiary
of Dutch publishing company Wolters Kluwer. Wolters
Kluwer is the third largest legal publishing company
in the U.S., after Thomson and Reed Elsevier
9 LexisNexis holds
a minority interest in Versuslaw, according to the "Legal
Publishers List."
10 These rates
were per the Versuslaw Web site in October 2002 at http://www.versuslaw.com.
11 All prices are
as of October 2002, according to the West Group and
LexisNexis Web sites.
12 Terry Carter, "Self-Help
Speeds Up," ABA Journal, July 2001, p. 34+.
13 Carol Ebbinghouse, "Not
All Laws Are Free: The Importance of the Veeck Case," Searcher:
The Magazine for Database Professionals, February
2002, vol. 10, no. 2.
14 Banks v. Manchester,
128 U.S. 244 (1888).
15 Banks v. Manchester,
128 U.S. 244 (1888), citing Nash v. Lathrop,
142 Mass. 29, 35.
The opinions expressed in this article are those
of the author and do not necessarily reflect the opinions
of her employer.
Melissa Barr's e-mail address is mbarr@cuyahoga.lib.oh.us
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