A headnote is a small paragraph at the beginning of a case which summarizes a portion of the case.  The headnote is not part of the opinion, and the headnote should not be quoted.  While some courts may provide headnotes, they are primarily a tool of private publishers such as West Publishing Company.  A headnote by West Publishing Company includes a reference to a Key Topic and Number.  This Key Number System may be used to access West Digests, which in turn provide the researcher with additional cases dealing with that topic.  Be aware that the Key Number () is different from the headnote number ()  The headnote number () corresponds with a specific portion of the case.  For instance, if the researcher wants to find the portion of the case that deals with headnote number 1, the researcher would look for a bracketed number 1 in the body of the opinion.