Three Good Sources or Three Good Searches for Legal Research

It is occasionally difficult to convince students of the wonder of research: you never know what you might find! At the same time, students who believe in that wonder sometimes believe that there can be no method at all, as magical research results must only lie at the end of long and tortuous journeys which can never be repeated or described. I believe that there are methods and patterns to research, but I also know that even while following simple principles the path of research often feels twisty. The One Good Case method is one of the simple principles that really works for my students: just find one good case and you can use research tools to expand from there.

I’d like to propose a new rule: the Three Good Sources rule. In my program, we tell our students to always begin their research with a secondary source. It’s a sensible rule, but it’s especially important in the Google era, as students are predisposed to search, search, and search again before considering other options. As students grow into more advanced researchers, they begin to encounter research problems which might require more than one secondary source to fully understand the scope of the issue, explore the issue across jurisdictions, and do a deep-dive into the subject matter. My colleague Brian Flaherty suggested that we ask our students to find three secondary sources for their current research assignment and the more I use this idea, the more I like it! I think that using three secondary sources for complex research would encourage students and researchers to think about how the three sources would complement each other, and that focus would lead to more careful, thoughtful research. The researcher should balance the tone, the expected audience, and the length of their sources. Or she could consider the timeliness of certain less-scholarly pieces balanced with more general (though less recent) scholarly publication. For example, a researcher might use:

  • A national treatise, a case-based encyclopedia, and a law review article
  • A bar journal, a law review article, and a treatise on the subject
  • A newspaper article, a law journal article, and a book on the history of the topic

Alternatively, I’m also considering a Three Good Searches rule. Unlike the Three Good Sources rule, which anticipates the three sources working together to create a research foundation, the three good searches would be more like goldilocks searches: search too broadly, too narrowly, and then delve into the results of the third search: the just-right search. When my students learn about the tools available to them, they often want to craft the perfect search, but the perfect search depends upon the results. Teaching students to run three searches might decrease their worry about crafting perfect searches from the get-go, while giving them time to slow down and see the effects of the changes they make to their searches.

When I’ve taught legal research for twenty years I may have a series of Twelve Rules of Legal Research, beginning with Twelve Terms and Connectors and singing all the way down to the One Good Case method, but while that still sounds a little ridiculous to me, I’m ready to suggest the Three Good Sources and Three Good Searches methods to my classes.


  1. Really good points and ideas. So timely when we really have to make our teaching more targeted and succinct, due to competition from phones, assigned work from day 1, that accompanies the arrival of students!

  2. When I was in law school, I was lucky enough to be paired with a state Supreme Court justice in a mentor-mentee program. Something he said always stuck with me: “It amazes me how much time lawyers spend searching through case law, when often there is a statute right on point.”

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