This Week in Legal History

I’m a day late for Throwback Thursday, but in the spirit of thinking about the past, here are some events from this week in legal history, along with some sources for legal history research. Fair warning: this is the kind of research it’s easy to lose a whole day on just because it’s really interesting.

This Week in Legal History

Image from Dred Scott Opinion

March 6, 1857: The U.S. Supreme Court’s opinion in Dred Scott v. Sanford issued, holding that because Scott was black, he was not a citizen and could not sue for his freedom. The case also held unconstitutional the Missouri Compromise, which restricted slave ownership in certain territories.

Photograph of Susan B AnthonyMarch 8, 1884: Susan B. Anthony testified in the U.S. House Judiciary Committee for the women’s suffrage and 19th Amendment.



Illustration of the revolt on board the slave ship Amistad.
Source: A History of the Amistad Captives by John Warner Barber. Electronic edition courtesy of UNC-Chapel Hill.


March 9, 1841: Amistad slave ship case decided by the U.S. Supreme Court.




Button saying old enough to fight old enough to voteMarch 10, 1971: Senate approves 26th Amendment to lower voting age from 21 to 18.



For more legal history events, see Jurist’s This Day at Law and Findlaw’s Today in Legal History.

Legal History Research

American Memory Project: “American Memory provides free and open access through the Internet to written and spoken words, sound recordings, still and moving images, prints, maps, and sheet music that document the American experience. It is a digital record of American history and creativity. These materials, from the collections of the Library of Congress and other institutions, chronicle historical events, people, places, and ideas that continue to shape America, serving the public as a resource for education and lifelong learning.” Many of these collections chronicle the history of legal issues and cases. For example, the Slaves and the Courts, 1740-1860 contains materials about the Dred Scott case, noted above.  Note that the Library of Congress is in the process of migrating the collections to a new digital collections platform and the legal materials are currently split between the platforms.

Famous Trials: This is an incredible collection of documents, images, testimony, timelines, news coverage, etc. of famous trials going back to the trial of Socrates in 399 B.C. This comprehensive collection is the work of Prof. Douglas O. Linder from UMKC School of Law. This collection includes materials on the trial and conviction of Susan B. Anthony for illegal voting, 13 years before her historic testimony before the Judiciary Committee, noted above.

Hein Legal Classics: The Legal Classics library on HeinOnline contains 6700+ historical law books, including books written by legal scholars like Joseph Story, Jeremy Bentham, William Blackstone, William Holdsworth, Henry Maine, Federick William Maitland, Frederick Pollock, and Benjamin E. Cardozo. The collection includes works dating as far back as pre-1700. HeinOnline is available to University of Montana students and faculty through the Law Library Databases web page.

Making of Modern Law, Legal Treatises 1800-1926: This digital collection includes casebooks, local practice manuals, form books, works for lay readers, pamphlets, letters and speeches that make it an invaluable research tool for 19th Century Anglo-American law. This database is also available to University of Montana students and faculty through the Law Library Databases web page. Other Making of Modern Law collections not available on the UM campus cover primary sources from 1620-1970, trials from 1600-1926, and U.S. Supreme Court records and briefs from 1832-1978.

Eighteenth Century Collections Online: 18th Century Collections Online is a database of full-text works published in England in the 18th century. The full collection is multidisciplinary and covers all academic topics, including almost 10,000 legal titles. This database is also available to University of Montana students and faculty through the Law Library Databases web page.

Legal History on the Web: Compiled by the Triangle Legal History Seminar, this is a comprehensive portal to everything legal history on the internet. In addition to a plethora of research sites, this site also links to scholarship, prizes, and jobs in legal history.

ABA Journal Precedents: ABA Journal’s Precedents feature highlights photographs of some of the most famous events in American law. Each month, the last page of the journal contains a summary and photographs. The Precedents feature is available online on the journals’ website.

Montana’s Early Women Lawyers: And for something local, Prof. Bari Burke’s blog provides insight into the history of women lawyers in Montana, and by extension, early women lawyers across the United States. For more information about this blog, see our earlier blog post, There’s a New Blog in Town.


Casetext: Making All the World’s Laws Free and Understandable.

Guest blogger Morgan Hoyt is a 2L student at the Alexander Blewett III School of Law. When he became a Casetext Ambassador, we asked him to blog about this new resource.

This spring semester, I became the first Casetext Ambassador at Alexander Blewett III School of Law. I did not know much about Casetext prior to applying for the position. I first heard about it through a classmate and immediately became intrigued after learning that Casetext was a free legal research platform powered by insights from the legal community. The concept of democratizing legal research was intriguing, and I decided to apply because I wanted to get involved. The more I use and work with Casetext, the more I see a future where this becomes the place where lawyers, professors, and law students come together to make the law free and understandable. I’m excited to be a part of helping to increase access to those who would otherwise not have it.

In its simplest form, Casetext is a legal research and writing platform. Its library includes over 8.3 million cases and statutes, and they already have over 500,000 users visiting the site each month. However, what makes Casetext different from other platforms is the commentary and analysis from real life members of the legal coScreenshot of case from Casetextmmunity linked directly to the cases they are discussing. This provides context and gives life to the text of the case that you are researching.

Casetext also has a host of unique features to further aid your research. One of these features is the Heatmap. The Heatmap is a visual aid that helps you quickly navigate a case. It is located on the left hand side of the case, and it appears as a segmented line with varying shades of blue. The darker the color of blue, the more often that section of the case has been cited to. To travel to that section of the case, simply click on that portion of the line. I regularly use this feature when I need to quickly navigate to the crucial sections of a case.

Another unique feature is Judicial Summaries. Judicial Summaries are concise summaries of the key aspects of a decision extracted from explanatory parentheticals. Casetext has used data science to extract these summaries, and who better to provide you with a summary of the case then a subsequent judge? Together with the Heatmap, these two tools add an additional layer of analysis to your legal research.

Outside of providing access to cases and unique tools to better understand them, you can write about the law using Casetext’s writing tool called LegalPad. LegalPad makes it possible for users to easily write about and connect their analysis directly to the law they are discussing. Generally, these posts are in reference to either a recent court case or regard the contributor’s area of expertise. A great example of this is Doug Hallward-Driemeier’s post regarding the Supreme Court’s decision in Obergefell v. Hodges merely nine days after the Court issued their opinion.

Casetext has organized thisscreenshot of Casetext communities page kind of analysis into legal communities. After signing up, users can follow the communities or legal practices areas they are most interested in (e.g. Criminal Law). Each community has a feed similar to one you would see on Facebook so you can stay up to date on what members of that legal community are currently talking about. In my opinion, this is one of the coolest features of Casetext because you can easily stay up to date, and this is a great resource for students who are looking for current topics to write on.

A final feature of Casetext I want to highlight is the WeCite project. The WeCite project demonstrates just how Casetext is truly driving the democratization of legal research. WeCite is Casetext’s version of Shepardizing, but they are building it through crowdsourcing. Last semester, Casetext developed the WeCite project into an exclusive contest for law students, and it has really taken off with students from over 100 law schools participating. It is really easy to get involved, and I encourage students to check it out. All students have to do is go to and sign up. You are then presented with a case and asked how a citation highlighted within that case is being treated. You then choose from one of four relationships to describe the relationship with points being awarded and prizes earned at certain milestones. As a student, I have found WeCite to be particularly helpful. By reading and analyzing citation treatments, my reading comprehension has greatly increased in both speed and accuracy, and I have also earned awesome prizes for my WeCites.

Overall, I have found Casetext to be extremely user friendly with a number of very useful features. It is easy to sign up and free. The access to the communities and blog posts alone make this service worth adding to your research routine. To sign up, head over to Do not hesitate to reach out to me if you have any questions or are interested in learning more about Casetext!

Mobile Law Apps: Part 1 – Best Apps for Law Students

Welcome to guest blogger Terry Gilham! Terry has recently joined the library staff as a part-time volunteer librarian. She will be blogging from time to time.

 Law Dojo logoLaw Dojo – Know Your Rights
For iPhone, iPad, and iPod touch; Android version coming
Basic game is free, individual games $2.99 each

This app provides a series of games that test a player’s knowledge of a number of law subjects. A free version covers in general all topics. Individual games are available for $2.99 for specific areas of the law such as, civil procedure, torts, contracts, Supreme Court, criminal law, etc. Designed by Margaret Hagen, a lawyer, it features cartoon illustrations   to underscore the philosophy of Law Dojo, that law can be fun.

Law in a Flash thumbnailLaw in a Flash
Compatible with iPhone, iPod touch and iPad and all Android devices.
$19.99 each for the full version of each specific areas of the law

This mobile app is essentially a digital version of the traditional flashcard model. It is ideal for reviewing legal topics by examining the essential elements of each legal concept. The app allows the user to download cards, read the questions or hypothetical situation on the front of the card and then tap the screen to flip the card over for the correct answer. In addition, the app allows one to enter personal study notes for each card using the touch screen keyboard. Cards that require further study can be bookmarked and saved using the “Study Set” feature.

Basic law school subject areas covered include Civil Procedure, Constitutional Law, Contracts, Criminal Law, Evidence, Professional Responsibility and Ethics, Property and Torts. Flash card versions are available for more advanced courses as well.

Law Stack thumbnailLaw Stack
Compatible with iPhone and iPad devices. Android version available. Free download with add-ons from $1.99.

This portable library is essentially a rule book containing the Federal Rules of Civil Procedure, Criminal Procedure, Appellate Procedure, Evidence and Bankruptcy. In addition it includes the U.S. Constitution.

Complete offline access is available for the downloaded titles. Other useful features include full-text searching, bookmarking, search highlighting, header only search option, context-sensitive searching, search history save, and email sections.

Fastcase mobile thumbnailFastcase HD
Compatible with iPhone, iPad and iPod Touch devices. Android version as well. Free download, but registration is required for accessing full features. Law students and faculty can use their free account provided through the Jameson Law Library.

This free legal research application contains cases and statutes from all 50 states and from the federal government. Searchable by citation, keyword (Boolean and natural language), or statute collection browsing. Results are presented with the most relevant appearing first. Search results are sortable and customizable and automatically display the number of citing cases. Users may go immediately to the most relevant paragraph of any case or statute and save favorite documents for later use. The site is updated daily.

WestlawNext mobile thumbnailWestlawNext
Compatible with iPhone, iPad and iPod Touch devices. Android version (has not received favorable reviews). The mobile app is free with a WestlawNext Account. Law students and faculty can use their law school Westlaw accounts.

The mobile app provides access to the resources of the Westlaw legal research system. Users can search the content of their database. Access features include WestSearch, Keycite, folders, history, document notes and highlighting. Additional mobile features include Westlaw alerts, the ability to track and follow companies of interest, customizable news feed and automatic updates for practice areas of interest. Users may save documents for offline reading, organize and share folders, access research history and email documents or selected text with a reference.

Law Dictionary thumbnailThe Law Dictionary & Guide
Compatible with iPhone, iPad, and iPod touch. Android version available.   Free download.

A mobile app that incorporates a searchable legal dictionary containing 8,500+ definitions, with a database of legal articles, FAQs, a lawyer directory, legal abbreviations and maxims. An “ask your legal question” with answers is also available. Content is updated continuously. The legal dictionary is available anytime offline. The legal guide requires an internet connection for accessing the web based guide to these materials.

Another Reason I Teach Legal Research

Photo of print case law reporters on a library shelf.A while ago, I wrote here about why I teach legal research and citation. My reasons for teaching research were: 1) legal research is the foundation of legal practice; 2) legal resources are unique; 3) being able to find the law empowers you to solve problems; 4) legal research is intellectually challenging and interesting; and 5) researchers change law. But as I am working today on an exercise for my students about research ethics, I realize I forgot one– attorneys have an ethical duty to not just research, but to research well.

The Montana Rules of Professional Conduct start with Rule 1.1, a lawyer’s duty of competence: knowledge, skill, thoroughness, and preparation.

A lawyer shall provide competent representation to a client. Competent representation requires the legal knowledge, skill, thoroughness and preparation reasonably necessary for the representation.

Rule 3.1 states that a lawyer

shall not bring or defend a proceeding, or assert of controvert an issue therein 1) without first having determined through diligent investigation that there is a bona fide basis in law and fact for the position to be advocated . . .  [or] 3) to extend, modify or reverse existing law unless a bona fide bases in law and fact exists for advocating doing so.

What I didn’t say in my earlier post is that legal research isn’t just foundational to legal practice because it’s a skill lawyers will use throughout their careers– it’s foundational because it’s a basic ethical duty that underlies our our relationship with our clients and how we represent our clients. And it’s not just that researchers change law, but that you have to research if you want to change law. Sometimes zealous advocacy requires arguing for a change in the law, but a lawyer can’t do that until he or she has researched and can support the argument that there is a reasonable basis for doing so.

Ethics don’t just require that in general lawyers are competent researchers but that they conduct the necessary research in every case. Rule 11 of the Rules of Civil Procedure state that

by presenting to the court a pleading, written motion, or other paper . . . an attorney . . . certifies to the best of the person’s knowledge, information, and belief, formed after an inquiry reasonable under the circumstances . . . (2) the claims, defense, and other legal contentions are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law . . .

Some cases will take more research than others. Likely, those cases where the lawyer is arguing for “extending, modifying, or reversing existing law or for establishing new law” will take a lot of research. But it will be interesting and important research, and if that’s what it takes to represent the client, that’s what the lawyer needs to do. And to take it back to my original post, I teach legal research because I don’t just expect that my students will be able to look up the laws; I expect that my students will be ethical lawyers and exceptional researchers who will contribute to the development of law because they know how.

drawing of leaf made of fall leaves and flowers

The Jameson Law Library blog will be taking a break next week for Thanksgiving.

Enjoy the holiday!

October 1

As of October 1, “[t]he soil series known as Scobey, of the taxonomic class fine, smectitic, frigid Aridic Argiustolls, is the official Montana state soil.” Also as of yesterday, Montana’s new hard-won bullying statute finally took effect. However, if you don’t have your own print copy of the Montana Code Annotated or have access to a library with a print copy, you may not know that because even though most laws passed by the 2015 Montana Legislature went into effect yesterday, yesterday there were no available electronic versions of the 2015 Montana Code Annotated (MCA). Today, Lexis and Bloomberg Law have the updated code. Westlaw and Fastcase still have the previous code, but they at least link to the updates– a good interim step between the end of the legislative session in April and the publication of the new code in October, though it’s not ideal and hopefully won’t be the status quo for long. Inexplicably, Montana Legislative Services, the publisher of the MCA, still has the 2014 MCA without even an indication that statutes may be out of date. The print versions of the 2015 MCA have been sitting on shelves for a couple weeks. The online version is usually published simultaneous to, if not before, the print version so it is a surprise that is has not yet been posted– a disappointing surprise.

Given that there is free print access to the MCA and at least some electronic access, this post may seem unnecessarily grouchy. But Lexis, Westlaw, Bloomberg Law and Fastcase all require that researchers have a subscription. They are excellent research services, but most Montanans cannot access them. Although the Montana Legislative Services online version is not an official version of the MCA, it is a reliable version and is virtually the only access many Montana citizens have to the laws that govern them. There is no requirement that the Code Commissioner publish the online version, but there is a  policy argument to be made that without the online version, Montanans constitutional right to participate and right to now are not given full effect.

The legislature doesn’t just pass laws for the sake of passing them, nor does Legislative Services publish them just because the legislature passed them. Laws affect people’s lives. The MCA is published because people really do need access to the laws. Publication of the MCA should not be the goal; providing access to the MCA to the citizens of Montana should be the goal.

We the People of Montana

1884 Preamble
1884 Montana Constitution

This is my favorite quote from the 1889 Montana Constitutional Convention transcripts:

I must say that the ladies are very fond of this smoky city, as [Butte] is sometimes called, because there is just enough arsenic there to give them a beautiful complexion, and that is the reason the ladies of Butte are renowned wherever they go for their beautiful complexions. (Laughter). … Now talking about this smoke, I believe there are times when there is smoke settling over the city, but I say it would be a great deal better for other cities in the territory if they had more smoke and less diphtheria and other diseases. It has been believed by all the physicians of Butte that the smoke that sometimes prevails there is a disinfectant, and destroys the microbes that constitute the germs of disease. … [I]t would be a great advantage for the other cities, as I have said, to have a little more smoke and business activity and less disease.

I can’t claim to have read the entire 974-page transcript, but this is such a gem I can’t help but declare it my favorite passage. It actually is a very small part of a wonderfully funny speech by the mining-magnate William A. Clark, who is not generally regarded by history as being funny. This passage is part of a debate about where the capitol should be located during which he extolled the virtues of Butte, then a bustling hub of mining activity.

Montana has had only two constitutions, the 1889 Constitution that established our statehood, and the 1972 Constitution. Montanans had also adopted earlier constitutions, one in 1884 in support of a bid for statehood, which was denied by Congress for political reasons, and one in 1886, the only copy of which was lost before it was even printed. One legend is that it fell out of a saddle bag on its way to Minneapolis where the closest printing press was.

The 1972 Montana Constitution has been touted for its progressive ideas that protect Montana ideals: privacy, public participation, liberty, human dignity, and environmental protection. This makes the Constitution an interesting document to research, both for the lawyers and politicians who apply its provisions and scholars who look to it as both a historical and modern legal document.

Constitutional researchers are usually trying to answer one (or both) of these questions: 1) how has a certain provision been interpreted and applied; or 2) what is history of this provision? Here are some helpful sources and research hints for researching the Montana Constitution.

  1. Start by looking up the provision in the Montana Code Annotated/Montana Code Annotated Annotations in print or on Lexis or Westlaw. The “annotations” (called “notes of decisions” in the electronic versions) are summaries of the cases that apply and interpret the provision you are looking at. If you are on Lexis/Westlaw, also look at the “credits” at the end of the provision. They will show which provisions originated in the 1889 Constitution which will help if you are going to look more into the background of the provision.
  2. Look for law review articles. Law review articles will provide a scholarly discussion of the provision. Montana Law Review is an especially good source for Montana constitutional issues, but look broader as well to see how the Montana Constitution is being discussed by scholars elsewhere. However, you have to be especially aware of the scope of your source. Westlaw only has Montana Law Review back to 1994 (with selected coverage back to 1985); Lexis only has it back to 1999. If you are trying to determine the contemporary discussion– what were scholars writing about the Montana Constitution when it was new– Lexis and Westlaw are not good sources. Instead, try the Scholarly Forum @ UM Law, which has full-text of all issues of the Montana Law Review back to the first and everything (almost) published by UM Law faculty regardless of where it was published.
  3. Read the debates in the transcripts of the 1972 Montana Constitutional Convention. Researchers are fortunate that there is a complete record of the Montana Constitutional Convention. The 8 volume set contains delegate proposals, committee reports, verbatim transcripts and an index that allows you to locate relevant portions of the debate by article and section. The Jameson Law Library has several copies of the print set and it is online courtesy of the State Law Library of Montana. In addition to the transcripts, the Library also has copies of the the memos, studies and occasional papers the delegates used as they were drafting and debating. These sources may provide insight into some of the sources and issues underlying the discussions.
  4. Research the ratification. When we research the “legislative history” of a statute, we are most often looking for the intent of the legislators who enacted the statute. Constitutions, however, are not enacted by a legislature– they are ratified by the people. Although the transcripts can provide insight into what the delegates discussed and what their concerns were and even what their intent was, the intent that may be most relevant is the intent of the people who ratified the Constitution. What did they think a particular provision meant? This is tricky (but really interesting) research. The Convention published a newspaper insert with the official text and brief explanations of the new new Constitution. This would have been widely distributed and likely was the document that would have been read by the largest number of people. Editorials and letters to the editors will provide great insight into what people were talking about and concerned with, but the discussions will be more localized. A historical newspaper database like the Access Newspaper Archive (available on the UM campus through Mansfield Library) is a good way to conduct this type of research. For coverage from Missoula, the Missoula Public Library has a searchable index to the Missoulian and both the Missoula Public Library and Mansfield Library have issues of the newspaper back to the earliest issues on microfiche.

A few other sources for your research:

  • 1889 Montana Constitution. The transcripts of the proceedings are available in print at the Jameson Library and the State Law Library but they aren’t online. The index to the Proceedings is online from the State Law Library.
  • 1884 Montana Constitution. The transcripts of the proceedings of the 1884 constitutional convention are available in print, but they are handwritten and not indexed.
  • Larry M. Elison & Fritz Snyder, The Montana Constitution: A Reference Guide (Greenwood Press 2001). This book is an excellent resource covering both the constitutional drafting & debates and constitutional interpretation.
  • Jameson Law Library Montana Legal Research webpage. The Montana Constitution section of this website links to many of the resources discussed above.
  • University of Montana Mansfield Library. Use the “Search library resources” search box to search for additional books and journals that discuss the Montana Constitution from other academic viewpoints.

Legislative Intent Part 2 – 1987-1995

In the last blog we learned that some of the most valuable documents in determining legislative intent are the committee hearing notes. The methods of accessing these hearing notes depend on the legislative year in question. Here is a breakdown of access methods for various legislative sessions:

Prior to 1987 – Contact the State Law Library or the Montana State Historical Society – no materials are available at the Jameson Law Library.

1987 to 1995 – Microfiche available at the Jameson Law Library (and at the Montana State Law Library).

1997 – Electronic access at the Jameson Law Library (and at the Montana State Law Library).

1999 to the present – Online.

We have already covered 1999 to the present. 1997 represents a special case where the documents are available at the law library – the best thing to do if you need committee hearing notes from 1997 is to contact a Jameson law library staff member.

Because we will no longer be dealing with documents that are available online, the following discussion will be limited to the holdings of the Jameson Law Library on the UM Campus. Other documents and other means of access are available from the State Law Library of Montana as outlined in The Montana Legislative History Research Guide.


Accessing committee hearings through microfiche uses many of the tools that we learned about in the last blog: committee names, hearing dates, and bill numbers. The difference is in how these items are located and how the documents are accessed. Here is an example of a law that was amended in 1987, 1995, 1997. Let’s look into the 1995 amendment.

16-2-301. Retail selling price on table wine — tax on certain table wine. (1) The retail selling price at which table wine is sold at an agency liquor store is as determined by the agent.
(2) In addition to the tax on wine assessed under 16-1-411, there is a tax of 1 cent a liter on table wine sold by a table wine distributor to an agent as described in subsection (1). This additional tax must be paid to the department by the distributor in the same manner as the tax under 16-1-411 is paid. The department shall deposit the tax paid under this section in the general fund.
(3) For the purposes of this section, “table wine” does not include hard cider.

History: En. Sec. 9, Ch. 699, L. 1979; amd. Sec. 1, Ch. 629, L. 1987; amd. Sec. 27, Ch. 530, L. 1995; amd. Sec. 3, Ch. 399, L. 1997.

The first step is to determine the bill that amended this law. To locate the bill information we consult the Legislative Review 1995 (REF KFM9015 L43 1995) and look at the “Summary of Provisions by Chapter” section. Chapters are listed in numeric order so looking at chapter 530 tells us that HB574 was the bill that amended this law in 1995.

1995 leg review

The next step is to look at the history of HB 574 located in the “House Bills and Resolutions” section of 1995 History and Final Status (REF KFM9015 A24 1995).     The History and Final Status will provide us with the committee names, and hearing dates that we need to navigate the microfiche.

1995 hist and final status

From the History and Final Status of HB 574, we learn that the bill was referred to the House Business and Labor Committee and that a hearing was held on 3/2/95. HB 574 was then referred to the Senate Committee on Business and Labor and a hearing was held on 3/21/95. A complete search for indications of legislative intent would include looking at all available testimony, exhibits, discussions, committee reports and executive actions. In practice many people limit their search to the committee hearings and executive actions (often contained in the committee report).

We now have what we need to begin navigating the microfiche. The microfiche is organized by year, then by House or Senate, then by committee name. On any given piece of microfiche, documents are arranged in chronological order and roughly grouped by bill number. The microfiche and reader at the Jameson Law Library are located on the north wall.

For example, looking at the House Business and Labor Committee fiche that covers 3/2/95, we find the following hearing notes (plus six more pages of discussion and testimony not reproduced here).

house hearing march 2

Looking at the Senate Committee on Business and Industry fiche that covers 3/21/95 we find the following hearing notes (plus nine additional pages of discussion and testimony not reproduced here).

senate hearing march 22

To see the executive actions on this bill from these committees, we would simply move through the microfiche to the Committee Report dates provided in the History and Final Status entry: March 7 for the House committee, and March 21 for the Senate committee.

In conclusion, although some people shy away from microfiche based legislative intent questions, it’s really not that bad. It takes a little longer and you have to come to the library to do a fiche based search for legislative intent but the procedure is essentially the same as a web based search.

In the Jameson Law Library the microfiche is located on the north wall. The Montana Legislative Committee Reports are in the light blue cabinet. The microfiche reader instructions are on top of the  microfiche reader.