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Ohio Secondary Sources Legal Research Guide: Citator Signals

Shepard's Editorial Phrases

Shepard's uses editorial phrases to further indicate what happened in a subsequent case.

Examples:  followed, criticized, distinguished, harmonized, explained, affirmed in part and reversed in part, abrogated, etc.

Identifies at a glance whether a case is overruled for one point of law, but followed on another, as well as if one jurisdiction followed but another overruled. Uncovers these splits of authority at a glance.

Citator Signals


LexisNexis (Shepard's)

Westlaw (Keycite)

Negative treatment: Case is not good law for at least one of its points (overruled or reversed) ;Statute has been amended or repealed

Questioned by: Citing opinions question continuing validity or precedential value of case because of intervening circumstances, including judicial or legislative overruling

Red stop sign

Orange Q

Red status flag
Caution: Case has some negative history (limited, criticized); Statute has section affected by pending legislation Yellow triangle Yellow status flag
Pending - The case is under review   Federal Notice of Appeal Flag
No Citing Cases    
Positive treatment: History or treatment of case has positive impact on your case (affirmed, followed) Green diamond with plus sign  
Case has some analysis which is neither positive nor negative A in blue circle: A= analysis  
Case has some history A in blue circle: A= analysis  
Case is cited, with no analysis I in blue circle  

Depth of Treatment


Depth of Discussion

The indicator displays 1-4 bars depending on the amount of discussion:

Cited (1 bar) - the document cites to the reference with minimal, if any, discussion

Mentioned (2 bars) - the document briefly mentions the cited reference

Discussed (3 bars) - the document discusses the cited reference with some measure of analysis

Analyzed (4 bars) - the document fully considers the cited reference

Depth of Treatment

> 1 page discussion

> 1 paragraph discussion

< 1 paragraph discussion

brief reference, usually string citation

Lexis Advance Phrase Level Indicators

  Lexis uses indicators to show how each paragraph of the citing case treated the case in question.  For example:

Law Review article