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Oregon Statute (ORS) Annotations: The Good, the Really Good, and the Awful

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Usually when one wants to “shepardize” an Oregon statute (i.e. look for subsequent cases or legal publications that have cited the statute), the results are fairly uniform whether you check the official ORS Annotations volume (print and online), Lexis-Nexis Shepard’s, or Westlaw Keycite. The results are not usually identical, but there is usually a lot of overlap and maybe a unique hit or two. But for the latest request we got 3 extremely different results for a single ORS statute, which shall not be identified for now in the interest of privacy.

1) The official ORS Annotations had 0 results – yup ZERO.
2) Shepard’s had 4 case citations (and a variety of non-case annotations).
3) Westlaw’s annotated statute (and KeyCite) has a zillion cases. (Well, not quite a zillion, but if you looked at the print ORSA volume, they covered more than 3 pages.)

There is always the “poor-man’s shepard’s,” which simply means you plug your statute citation into a Oregon case law database and run with it.

Here’s the legal research lesson: Don’t let any one publisher do your research for you, especially when results seem puzzling or even just a little different from what you might have expected.