A fall associate walks into a partner’s office and sits down. The partner then explains the confusing background of a case the firm is handling in the federal district court for the Northern District of Illinois (within the 7th Circuit). After fifteen minutes, the partner gets to the research assignment: “I need you to find out how the courts in the 7th Circuit have handled the issue of whether a company’s website can serve as the basis for subjecting it to personal jurisdiction in a particular place.” The fall associate, feeling too intimidated to ask for advice, quickly leaves the office, with some basic thoughts on how to start the research.
Option #1: “Secondary Sources”
The associate knows that treatises can provide a quick and authoritative summary of the law, as well as contain citations to leading cases on particular issues, so the associate decides to try a search through one.
Using the Federal Litigation Research Tasks, the associate goes to the Treatises & Analytical Materials task box, selects Moore’s Federal Practice – Civil and enters a search of “website or web site /10 jurisdiction.”
One of the sections retrieved is 108.44 and is titled “Application of Jurisdictional Analysis to Situations Involving Internet.” The associate reads Moore’s analysis of the issue and then clicks on footnote reference 2 in order to jump to that footnote.
No cases from the 7th Circuit are listed in footnote 2, but the associate decides to read Neogen Corp. v. Neo Gen Screening, a case from the 6th Circuit, to get a better understanding of how specific courts are treating the issue. The associate clicks on the link for the Neogen case and, once the opinion appears, reviews the LexisNexis Headnotes. Headnote 9 looks like a good general statement of the law, so the associate selects the More Like This Headnote link for Headnote 9, and chooses to search through the 7th Circuit, Appeals & District source (in the “Combined Federal Courts” dropdown.)
After the list of cases appears, the associate decides to re-sort by Court/Date and, when he/she does so, discovers several very recent decisions from both the Northern District of Illinois (Ice Consultants US, Inc. v. Microvoice Applications, Inc.) and the 7th Circuit (Jennings v. AC Hydraulic A/S) that address the issue.
Option #2: Mealey Publications
The associate recognizes that, while Mealey’s Publications can serve as great tools for investigation of expert, judges and more, those articles can also provide insight into the latest legal developments.
At the Federal Litigation Research Tasks page, the associate simply goes to the main search box, types in “website or web site /10 jurisdiction” and selects the All Mealey Publications radio button.
One of the articles retrieved is titled “Floor Jack Crush Case Can‘t Be Litigated In Indiana, 7th Circuit Panel Finds,” and discusses Jennings v. AC Hydraulic A/S, a case from the 7th Circuit.
Option #3: Topic or Headnote
The associate learned how to search by Topic or Headnote in law school and believes it is far superior to the competitor’s digest system for its ability to retrieve not only reported decisions but also unpublished ones.
The associate selects the Topic or Headnote tab at www.lexis.com. Knowing that this particular issue deals with personal jurisdiction, the associate types in “personal jurisdiction” in the box under Option 1: Find a Legal Topic.
Of the ten results retrieved, the “Personal Jurisdiction” topic, under “Civil Procedure > Jurisdiction > Personal Jurisdiction & In Rem Actions” looks the most promising. To confirm, however, the associate clicks on the i (a.k.a. Information) button to the right of the topic. The Content Summary that appears indicates that this topic is precisely what the associate needs, so the associate selects the topic.
At the next screen, the associate selects the 7th Circuit – Federal & State Cases, Combined source in Step 1, enters a search of “website or web site /10 jurisdiction”in Step 2, and clicks on Search. One of the first cases retrieved is Jennings v. AC Hydraulic A/S, from the 7th Circuit.
Option #4: Statute Annotations
The associate’s Civil Procedure professor in law school emphasized the importance of jurisdiction and venue in litigation, so the associate is well aware that the federal statute governing jurisdiction is 28 U.S.C. 1391 and decides to pull it in order to see if any of the annotated cases might be relevant. The associate selects the Get a Fed. Document by Cite link on the right side of the Federal Litigation Research Tasks page.
At the next page, the associate uses the U.S.C. template to enter the statutory cite and then clicks Go.
When the statute pulls up, the associate pulls up his/her browser’s “Find” tool and types in “website.” The first casenote retrieved doesn’t seem quite on point, but the second one, for First Tenn. Nat’l Corp. v. Horizon Nat’l Bank, looks promising.
he associate clicks on the link for the First Tenn. case and reviews the LexisNexis Headnotes. Headnote 8 looks like a good general statement of the law, so the associate selects the “More Like This Headnote” link for Headnote 8, chooses to search through the “7 th Circuit, Appeals & District” source (in the “Combined Federal Courts” dropdown), and clicks on “Search.“ After the list of cases appears, the associate decides to re-sort by Court/Date and, when he/she does so, discovers several very recent decisions from both the Northern District of Illinois ( Ice Consultants US, Inc. v. Microvoice Applications, Inc.) and the 7th Circuit (Jennings v. AC Hydraulic A/S) that address the issue.
Option #5: A Case Opinion
Knowing that one of the key differences between Shepard’s® and other citators is Shepard’s true “positive” signal 
, the associate decides to Shepardize® a case he knows has dealt with the issue to be researched: Mink v. AAAA Dev. LLC, 190 F.3d 333 (5th Cir. 1999).
Upon Shepardizing the case, the associate uses the lower navigation bar to jump to the cases from the courts in the 7th Circuit that have cited Mink. Jennings v. AC Hydraulic A/S is the first case listed, and the Shepard’s report shows that Jennings actually followed Mink.
Option #6: Boolean Search
The associate feels pretty confident that he/she can run a regular Boolean search and find some relevant cases. So, the associate looks under the Template Searching options on the right side of the Federal Litigation Research Tasks page and selects Cases.
In the Court of Appeals, District Court and Bankruptcy Cases task box on the next page, the associate selects 7th Circuit from the first drop-down box and enters “website or web site /10 jurisdiction” as the search terms.
One of the opinions retrieved is Jennings v. AC Hydraulic A/S.
An old saying goes “there’s more than one way to skin a cat,” and the same holds true for conducting legal research at www.lexis.com. As demonstrated by the example, part of the power of the LexisNexis Total Research System is the amount of flexibility you have when starting your research. The associate could have utilized any one of the above options to start the research —all of which would have led to the same on-point case.