QuickLaw vs. LexisNexis – Canadian Coverage

It was always my understanding that QuickLaw’s Canadian case law coverage was equal, if not superior, to LexisNexis’. If you too were operating under that assumption, then the following may surprise you… 

I had found a reference to a case using the Nadin-Davis Sentencing Digest. Unfortunately, no citation was provided; it did, however, list the name of the case, the date (1986), the judge and the level of court. The digest entry also mentioned that the case had been appealed. So I set about to search for the case. 

I turned first to QuickLaw. I searched by case name and jurisdiction using the Court Cases search page and the All Canadian Court Cases database. In this way, I located the appellate decision, but it did not provide any further information (or a link) to the original sentencing decision. So then I searched by the judge’s name and date. Still nothing. Later, I found a Weekly Criminal Bulletin digest for the case (searching All Canadian Digests – as the WCBs are not included in the All Canadian Court Cases database), but not its full-text.

I tried similar searches using eCarswell. I consulted the hardcopy Canadian Case Citations (which is always a joy when searching for a criminal case). Neither of these searches produced any further information about my case. 

Our librarian then suggested that I try LexisNexis. And lo and behold, there was the full-text of my case! It was contained in the WCBJ database. 

I then contacted QuickLaw to ascertain why this decision was available through LexisNexis but not QuickLaw. I was informed that “this is the only case law source that we have different from Lexis.com.” Just my luck! 

So, if you are looking for a Canadian criminal case from the 1980s, you may wish to consult LexisNexis if QuickLaw doesn’t produce any results, or only gives you a WCB digest. QuickLaw’s WCB database “contains digests of criminal court judgments prepared by Canada Law Book since 1976.” LexisNexis’ WCBJ database “contains the unedited fulltext judgments and headnotes or all available criminal cases from courts across Canada since 1980.” I thought it was particularly interesting that this was a Canada Law Book product. 

Have you had any similar experiences regarding gaps in QuickLaw’s coverage that are filled by LexisNexis? If so, please advise.