West Key Number System 
Having Fun with the Digests!
Start with Cases
 A court issues an opinion in a case.
 A copy of the case is obtained by West
 Editors read the cases and pick out the points of
law addressed in the case.
 Written as a short, concise paragraph, these are
called headnotes.
Headnotes
 One point of law for each Headnote.
 Each Headnote has a Key Number
Headnotes
 Each Headnote will get a number before it like [1]
Headnotes
 Each Headnote will get a number before it like [2]
 You can find what that Headnote is referring to
by looking for the [#] in the body of the case.
 For example, if you hit [3], it will take you to
the part of the decision where that rule is
Key Numbers
 The Key Number System is big interactive outline
that works like this:
 First, the American system of law is broken down
into Major Topics
 there are more than 400, including things like:
 Civil Rights,
 Pretrial Procedure, and
 Criminal Law.
Key Numbers
 Each of those topics is divided, in greater and
greater detail, into individual units that represent a
specific legal concept.
 like steps in an outline.
Key Numbers
 Each of the lines (more than 80,000 of them) has
a unique number that allows you to find it on the
outline.
 This number is called a Key Number.
 The whole outline, along with the case headnotes
classified to it, is called the Key Number System.
 The Key Number System is found in the Digests.
 We use the New York Digests
Scenarios
1) Corpus Juris Secundum to Cases
2) Cases to Better Cases
Scenario 1
 PROBLEM: What are the elements of
negligence in New York?
 You want to find the New York elements of
negligence
 You can either look in
 New York Cases or
 Corpus Juris Secundum (You can also look in
New York Jurisprudence 2d Series)
Corpus Juris Secundum (CJS)
 Elements of Negligence
 SEARCH TERMS AND CONNECTORS:
Elements /s Negligence
1
3
2
CJS
 You get 220 hits
CJS
 What do you look for?
 You look for the topic of “Negligence”
 Scroll down
CJS
 What did you get?
 The essential elements for an action in negligence
are that the defendant was under a duty to protect
the plaintiff from injury, that the defendant
breached that duty, that the plaintiff suffered
actual injury or loss, and that the loss or injury
proximately resulted from the defendant's breach
of the duty.
CJS
 The essential elements for an action in negligence
are that:
1) defendant was under a duty to protect the
plaintiff from injury,
2) defendant breached that duty,
3) plaintiff suffered actual injury or loss, and
4) loss or injury proximately resulted from the
defendant's breach of the duty.
CJS
 BINGO!
CJS
 BINGO?
 No exactly
 Corpus Juris Secundum is a secondary source
of law
 You need primary
CJS
 CJS to Primary
 Two ways
 Footnotes
 Key Number
CJS
 CJS to Primary
 Two ways
 Footnotes (there are no footnotes in this text)
 Key Number
CJS
 CJS to Primary
 Two ways
 Footnotes (there are no footnotes in this text)
 Key Number
CJS to Cases
CJS to Cases
CJS to Cases
CJS to Cases
CJS to Cases
105 Headnotes
From the
Most
Recent
Which Courts are
these from?
Which Courts are
these from?
Which Courts are
these from?
Appellate Division,
Second Department,
2011
Which Courts are
these from?
Which Courts are
these from?
Court of Claims, 2011
Which Courts are
these from?
Which Courts are
these from?
Court of Appeals, 2011
Which Courts are these from?
Appellate Division,
Second Department,
2011
Court of Claims, 2011
Court of Appeals, 2011
Which one should you look at?
Appellate Division,
Second Department,
2011
Court of Claims, 2011
Court of Appeals, 2011
LOOK FOR HIGHEST COURT
Appellate Division,
Second Department,
2011
Court of Claims, 2011
Court of Appeals, 2011
LOOK FOR HIGHEST COURT
Appellate Division,
Second Department,
2011
Court of Claims, 2011
Court of Appeals, 2011
CJS TO CASE
CJS TO CASE
LOOK FOR THE
HEADNOTE THAT
PERTAINS TO THE
ELEMENTS OF
NEGLIGENCE
CJS TO CASE
CJS TO CASE
CLICK ON THE [3] TO GET
TO THE PART OF THE
DECISION WHERE YOU
MIGHT SEE THE ELEMENTS
CJS TO CASE
CJS TO CASE
Not enough:
get this case
Not what I am looking for
CJS TO CASES
 GO BACK TO THE DIGESTS
 Hold down left (back) button on your browser.
 On drop down look for Digest.
 Go from there
This looks
promising
CJS TO CASE
 To prove a prima facie case of negligence, a
plaintiff must demonstrate the existence of a duty
of care owed to the plaintiff, a breach of that duty,
and that the breach of such duty was a proximate
cause of his or her injuries ( see Pulka v.
Edelman, 40 N.Y.2d 781, 390 N.Y.S.2d 393, 358
N.E.2d 1019; Gordon v. Muchnick, 180 A.D.2d
715, 579 N.Y.S.2d 745; see also Akins v. Glens
Falls City School Dist., 53 N.Y.2d 325, 333, 441
N.Y.S.2d 644, 424 N.E.2d 531).
CLEAN IT UP
 To prove a prima facie case of negligence, a
plaintiff must demonstrate the existence of a duty
of care owed to the plaintiff, a breach of that duty,
and that the breach of such duty was a proximate
cause of his or her injuries ( see Pulka v.
Edelman, 40 N.Y.2d 781, 390 N.Y.S.2d 393, 358
N.E.2d 1019; Gordon v. Muchnick, 180 A.D.2d
715, 579 N.Y.S.2d 745; see also Akins v. Glens
Falls City School Dist., 53 N.Y.2d 325, 333, 441
N.Y.S.2d 644, 424 N.E.2d 531).
CLEAN IT UP
 To prove a prima facie case of negligence, a
plaintiff must demonstrate the existence of a duty
of care owed to the plaintiff, a breach of that duty,
and that the breach of such duty was a proximate
cause of his or her injuries (see Pulka v Edelman,
40 NY2d 781; Gordon v Muchnick, 180 AD2d 715;
see also Akins v Glens Falls City School Dist., 53
NY2d 325, 333).
CLEAN IT UP
 To prove a prima facie case of negligence, a plaintiff
must demonstrate
1) the existence of a duty of care owed to the
plaintiff,
2) a breach of that duty, and
3) that the breach of such duty was a proximate
cause of his or her injuries (see Pulka v Edelman,
40 NY2d 781; Gordon v Muchnick, 180 AD2d 715;
see also Akins v Glens Falls City School Dist., 53
NY2d 325, 333).
CLEAN IT UP
 The elements of negligence are:
1) the existence of a duty of care owed to the
plaintiff,
2) a breach of that duty, and
3) that the breach of such duty was a proximate
cause of his or her injuries (see Pulka v
Edelman, 40 NY2d 781; Gordon v Muchnick,
180 AD2d 715; see also Akins v Glens Falls
City School Dist., 53 NY2d 325, 333).