When we had only Shepard's, we told students about the occasional problems
with Shepard's and reminded them that they still needed to be observant in
their research because Shepard's didn't catch everything. To some extent,
we may be lulled now into thinking that if neither Shepard's nor Keycite
finds anything negative, the case must be solid. As a student of mine
found in his final paper, the old warning is still valid. Lingefelt v.
Hammer, 125 So.2d 325 is a case from the 1960's involving liability for
injuries from an accident where the vehicle at fault was stolen when the
key was left in the ignition. Vining v. Avis, 354 So.2d 54 is a later
case in which the Florida court made a major shift in how these cases were
handled. It implicitly overruled Lingefelt, but you can't tell that by
either Shepardizing or Keyciting. Table of Authorities in Keycite does
not indicate the problem although from looking at some other key cite
entries, I would expect to find that either Lingefelt or one of the cases
it relied upon would have a keycite code of cast into doubt.
Mary Brandt Jensen University of Mississippi
Director of the Law Library University, MS 38677
Assistant Professor of Law mjensen@olemiss.edu
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