1. Digest Paragraphs, Headnotes and Statutory Annotations

2. Headnotes
Cases as reproduced in the National Reporter System® are a combination of primary and secondary authority.
The opinion of the court is primary law.
The editorial enhancements, such as the synopsis and the headnotes, are secondary law, that are
summaries of the opinion
written by West attorney-editors
written in universally recognized legal terminology in place of outdated, slang, or regional words or proper names
Both headnotes and key numbers are in the digest (di) field in Westlaw case law databases.
Database: any case law database
Search: di(“social host” /p liab!)

3. Digests
A headnote is assigned to a West Key Number reflecting a specific point of law.
Digest paragraphs are headnotes from cases arranged alphabetically by topic and then numerically by Key Number.
Digests ease the retrieval of cases in any jurisdiction that have addressed the same point of law.

4. Statutory Annotations
Annotations (Notes of Decisions) are summaries of case law that has interpreted, explained, or analyzed the language of a statute.
They follow the text and research aids in statutory materials.
West statutory materials use the headnotes from relevant cases to annotate a statute as published by West.
The annotations are secondary resources.
Do not cite the language of headnotes, digest paragraphs, or annotations as primary law.
They are to be used only as a way to find relevant cases.

5. The language of the Case Headnote, the Digest Paragraph, and the Statutory Annotation is identical.
The language of headnote
number 2 of the Koehnen
case. It references Minnesota statute 340A.801
The language in the digest
paragraph that refers to headnote 2 of the Koehnen case.
The language of the annotation
to Minnesota Statute 340A.801
that refers to the Koehnen case.