Statutory research complete_show2

STATUTORY RESEARCH
West’s Instructional Aid Series

CONTENTS
• Introduction
• The Legislative Process
• Anatomy of a Statute
• Statutory research: Print and Online
• Updating Statutory Research
• Expanding Statutory Research
– KeyCite®
– Case Law (Annotations)
– Legislative History
– Secondary Sources

INTRODUCTION – SOURCES OF AMEICAN
LAW
• Statutory Law is enacted by
Legislatures.
• Case Law is decided by the Courts.
• Regulations are issued by the
Executive Branch (Agencies).

INTRODUCTION – FEDERAL STATUTES
• Federal statutes are codified in the
United States Code.
– The United States Code (USC) is
the official version of the statutes
and is published by the
Government Printing Office.
– The United States Code
Annotated® (USCA)® in print is
published by West.
– USCA is the database on
Westlaw® that contains the USCA

INTRODUCTION – STATE STATUTES
• Each state has a statutes publication.
The publication might be called
statutes, statutes
annotated, laws, code, or code
annotated. The annotated versions
enhance your ability to find relevant
cases and statutes.
• XX-ST-ANN (where XX is the state’s
two-letter postal abbreviation) is the
database identifier for annotated
state statutes on Westlaw.

INTRODUCTION – STATE LEGISLATIVE
PROCESSES
• Most state legislatures are modeled after the
United States Congress and consist of two houses.
Only Nebraska has a one-house legislature.
• Legislation moves through state legislatures in
much the same way it moves through Congress.

• The governor signs or vetoes the legislation and
there are state provisions for overriding a
governor’s veto.
• What is said about the federal legislative
process is usually true of state
legislative processes.
The model for this presentation
will be the federal statutes.

STATUTES: THE NEGLECTED SIDE OF
LEGAL RESEARCH
• Most of what you learn in school will be based on
the common-law traditions of the courts.
• Statutory law is often obscurely or ambiguously
worded.
• It must be interpreted by case law.
• This case law often becomes a more accessible
source of law than the statute.
• Statutory research may seem complicated. This is
due, in part, to the fact that most researchers are
not trained in statutory research.

STATUTES ARE THE NEGLECTED SIDE OF
LEGAL RESEARCH BUT…
• Statutes are around to stay. They are the
cornerstone of our legal system.
• Only a court of competence can declare a clearly
worded statute unconstitutional.
• Don’t fight them. There is help!

THE LEGISLATIVE PROCESS
• Introduction of a bill (proposed legislation)
• Passed by both houses of Congress
• Signed by president or president’s veto is
overridden
• Becomes a “session law” or “public law”
• Incorporated into statutory code

THE LEGISLATIVE PROCESS: A BILL IS
INTRODUCED
• A bill is introduced by a sponsor(s) in one or both
houses of Congress.

• A bill is assigned a bill number (H.R. 14, 107th
Cong., 1st Sess. (2001)).
• This bill number usually follows the proposed
legislation through
hearings, amendments, congressional
committees, etc., until enactment or the end of
the current legislative period.

INTRODUCED
• A companion bill may be introduced in the other
house of the legislature at any time.

• Committee hearings may be held and amendments
to the bill may be made. If the committee votes
favorably on the bill, a committee report in support
of the bill accompanies the bill back to the floor in
many jurisdictions.
• A bill may die in committee and never reach the full
house for vote.

INTRODUCED

Bill S. 940
Sponsors
Short Title

• Federal bill S. 904 (Leave No Child Behind Act of
2001), sponsored by Senators Dodd, Wellstone, and
Kennedy, as it appears in the Congressional Bills – 107th
Congress database.

THE LEGISLATIVE PROCESS: A BILL
BECOMES LAW
• When the bill passes one house, it is sent to the
other house for consideration.

• The other house may approve and pass the bill to
the president in identical form.
• More likely, the other house will propose a variation
of the bill and both houses must negotiate a
compromise.
• When both houses pass the bill in identical form, it
is sent to the president for a signature or veto.

THE LEGISLATIVE PROCESS: A BILL
BECOMES LAW
• If signed (or not vetoed within 10 days), the bill
becomes a “session law” or “public law.”

• If the president vetoes the bill, the veto may be
overridden by two-thirds majority in both houses. (If
the president takes no activity on the bill at the end
of a legislative session the bill is, in effect, vetoed.
This is called a “pocket veto.”)
• The public law is renumbered using the number of
the congressional session and the numerical order
in which the law was enacted:
– P.L. 107-14 and P.L. 107-15 are the 14th and 15th bills to
be enacted by the 107th session of Congress.

THE LEGISLATIVE PROCESS: A PUBLIC
LAW MAY…
• add a section (statute) in the statutory code,
• change language in a section (statute),
• repeal a section (statute) of the statutory code,
• re-number a section (statute),

• Or do all of the above

LAW IS PUBLISHED
• An enacted law is first published officially by the
Government Printing Office as an individual slip law
and sent to government depository libraries and
other libraries that subscribe to these publications.
• Public laws are published in compiled volumes in
chronological order in The Statutes at Large, the
official government publication. There is a two to
four-year lag in publication of these volumes.

LAW IS PUBLISHED
• The U.S. Code
• Public laws are
Congressional and
also published in
Administrative News®
the USCCAN
(USCCAN), published by
and US-PL
West, issues monthly
(United States
pamphlets including newly Public Laws)
enacted laws.
databases on
Westlaw.
• The monthly USCCAN
pamphlets are reissued in
bound volume after each
congressional session.

LAW IS PUBLISHED

• A slip law as it appears on Westlaw in the US-PL database
shortly after enactment. There are also archived public
laws in the US-PL-OLD database, which contains public
laws from 1973 to the previous session of Congress.

LAW IS CODIFIED
• The public law then changes the statutory
code to:
– bring all laws on the same topic together

– eliminate all repealed or expired statutes
– unite amendments with the original statute

• This process is called codification
– the United States Code is divided into 50 titles, often
called codes (see next screen)

– Title 11 is the Bankruptcy Code

– Title 26 is the Tax Code

THE LEGISLATIVE PROCESS: THE
UNITED STATES CODE
• United States Code is
organized in broad
subject categories
called titles. The 50
titles are in rough
alphabetical order.

THE LEGISLATIVE PROCESS: THE
UNITED STATES CODE

• Each title is further divided into individual
sections, which contain the actual text of the statutes.
(The words section and statute are usually
synonymous.)

THE LEGISLATIVE PROCESS: CHANGES
TO THE UNITED STATES CODE
• A public law may amend/affect sections in different USCA titles
• The Public Safety Officer Medal of Valor Act of 2001 or P.L.
107-12 amended sections in Titles 42 and 15 of the USCA.

THE LEGISLATIVE PROCESS:
CODIFICATION TO THE U.S. CODE

Sections
in the
public law

Public Law 106-120, the Intelligence Authorization Act for the Fiscal
Year 2000, has been codified in both Title 50 and Title 21 of the United
States Code. The USCA-POP (USCA Popular Name Table) database on
Westlaw shows where a public law section has been codified in the
United States Code Annotated.

SUMMARY OF THE LEGISLATIVE PROCESS

Bill Passes
Congress or
State Legislature

President or
Governor
Signs Bill

Session Law/
Public Law

Statutory
Code

Codification occurs when the language of the session or public law changes
the statutory code in some way.

QUESTION
Which of the following is a true statement?
1.

Each public law amends a single statute.

2.

A slip law is the final version of a statute.

3.

Codification is the process in which sections of
public laws amend, add to, or repeal the
relevant portion(s) of the United States Code.

4.

The president’s veto of a bill may be overridden
by a majority of both houses.

ANATOMY OF A STATUTE: THE U.S. CODE
The United States Code (USC)
• Is issued every six years
• Is updated annually
• Is arranged into 50 titles
• References the Statutes at Large citation
• Includes historical notes and cross-references to
related sections
• Includes an index, a table of acts cited by popular
name, and conversion tables that allow you to
move between the present version and earlier
versions of the Code

ANATOMY OF A STATUTE: THE U.S. CODE
• The United States Code (USC), as published by the
government, has several drawbacks
–
–

There is a publication lag, especially for the annual
supplements.
There are no references to interpreting case law.

• The meaning of a statute is often unclear and must
be interpreted by the courts. The decisions of the
courts often become more important sources of law
than the text of the statutes.

ANATOMY OF A STATUTE: THE UNITED
STATES CODE ANNOTATED (USCA)
• The USCA contains the text and features of the
statute as they appear in the USC, plus:
– references to legislative history, and federal regulations
– references to the West Key Number System
– references to law review and journal commentaries
– library references
– references to texts and treatises
– Notes of Decisions (annotations)


Citation :
18 USCA 241

The text of the statute in the USCA is unchanged from how it appears in
the USC, as published by the Government Printing Office.

Credits (Text Amendments) are
past session laws that enacted or
modified the statute.

Historical and
Statutory Notes (Editor’s
Notes) are compiled by West
attorney-editors and give a
more detailed legislative
history of the statute.

Cross-references
(to other USCA sections)
Library references (to
many secondary sources)
References to topic
and key numbers

ALRs and
Encyclopedias

Texts and treatises


Index to the Notes of
Decisions
(annotations). Subjects
are listed
alphabetically

• Notes of Decisions
(annotations) are
summaries of how
courts have interpreted
the statute with links to
the case law.
• Notes of Decisions
are the headnotes from
cases that West
attorney-editors have
identified as
significantly interpreting
or applying the statute.

QUESTION
Notes of decisions are also called:
1.

Headings

2.

Annotations

3.

Credits

4.

Statutory history

STATUTORY RESEARCH: PRINT & ONLINE
• An alphabetical General
Index aids you in finding
relevant statute sections.
– The index has “access
words” that crossreference formal index
headings.
– The Index references
the relevant title(s) and
section(s) (statutes).

• The Popular Name
Table, in the last index
volume, helps determine
where a public law was
codified.

Popular Name
Table

STATUTORY RESEARCH: PRINT & ONLINE
Sarah Jones has finished law school, passed the
bar, and found a job with a legal aid service. Four
years of college and three years of law school
have run her student loan debt to well over
$100,000 and her salary will never stretch to make
the payments on that amount.

Sarah is considering filing for bankruptcy.
Could this extreme measure solve Sarah’s
problem?

STATUTORY RESEARCH: ONLINE AND
THE FIND FEATURE
• There are several different but effective ways to find the
Exceptions to Discharge in Bankruptcy statute (section).

• If Sarah knows the citation of the discharge statute, she
can simply type it in the Find this document by citation:
text box on the Paralegal page or click the Find link on
the toolbar.

Find

STATUTORY RESEARCH: FINDING A
STATUTE BY CITATION ON WESTLAW.COM
• You can type the following in the Find this
document by citation: text box:
– Enter xx st nnn.nn (where xx stands for the
state’s two-letter postal abbreviation and nnn.nn
stands for the citation number)
– Example: mn st 313.01 (do not include
paragraph letter or number, as in 313.01(a)(4))
• For code states or other states with irregular
numbering, simply type xx st in the Find this
document by citation: text box. See next screen.

STATUTORY RESEARCH: STATE STATUTE
TEMPLATES
• A template for the state’s
statutes is displayed.

• Just type in the statute
number in the appropriate
code’s text box.
• Click GO beside the text box
and you will retrieve the state
statute, in this case, Texas
Agricultural Code, section
41.002.

STATUTORY RESEARCH: DOCUMENTS IN
SEQUENCE ON WESTLAW.COM
• If Sarah isn’t sure she retrieved the correct section but
believes she is very close to it, she can use the
Documents in Sequence feature by selecting Previous
Section or Next Section links at the top of the screen.

STATUTORY RESEARCH: DOCUMENTS IN
SEQUENCE ON WESTLAW.COM
• Now you are viewing 11 USCA 524.
• The Documents in Sequence arrows allow you to move
forward or backward, statute by statute, just as if you
were paging through the statutes in print.

STATUTORY RESEARCH: TABLE OF
CONTENTS ON WESTLAW.COM
Sarah could also access
the Table of Contents
service, which is
available for each
statutory database on
Westlaw and open it to
the desired section.
The Table of Contents
service is also a great
way to browse the
sections around the
desired statute to see if
they any have relevance
to Sarah’s situation.

11 USCA 524

STATUTORY RESEARCH: CAPTION &
PRELIMINARY FIELD SEARCHING
• If Sarah knows that Title 11 is the bankruptcy title and she
needs the exceptions to discharge statute, the following
field restricted search using terms and connectors would be
effective:
ca,pr(“title 11” & exception)

• This search retrieves 11 USCA 523. The terms can be in
either the caption or the preliminary fields.
Prelim (pr)
field

Caption (ca)
Field

STATUTORY RESEARCH: DIGEST FIELD
SEARCHING IN CASES
• Sarah could try a Terms and Connector search in the
digest field of a case law database. (Here we will use the
ALLFEDS database.)
• For example: di(discharg! /p "student loan”)
This search yields
many cases and
several relevant
key numbers
related to 11 USCA
523.

STATUTORY RESEARCH: DIGEST FIELD
SEARCHING IN CASES

51k3371(1)

Sarah notices
that one
headnote states
that undue
hardship is the
only basis for
discharging
student loans.
11 USCA 523

• The key number 51K3371(1) assigned to this headnote
links to other cases discussing the same point of law.
Sarah will have to examine these cases to determine if
her situation can be considered a “hardship.”
• There are also references to the controlling statute(s).

STATUTORY RESEARCH: NATURAL
LANGUAGE SEARCHING
• Sarah could run a Natural Language search, which
can be very effective in annotated statute database, in
that.
• The looser structure of a natural language search will
often be more successful than a terms and connectors
search in capturing the unpredictable language of a
statute.
• The search:
– can student loans be discharged in bankruptcy

retrieves the Notes of Decisions shown on the next slide.

Student loan

educational loan

11 USCA 523 is the first document displayed. The “best” portion of
the statue is in the annotations. Sarah retrieved this document
even though the text of the statute does not mention a student loan
exception to discharge in bankruptcy. The annotations use
“student loan” and the text of the statute uses “educational loan”.

STATUTORY RESEARCH: USING
KEYSEARCH TO FIND STATUTES & CASES

• If Sarah is unfamiliar with both the language of the
law and key numbers, Key Numbers could be the
place to start research.

STATUTORY RESEARCH: USING
KEYSEARCH TO FIND STATUTES & CASES

• KeySearch divides the law into widely recognized
areas of the law, such as Bankruptcy.

STATUTORY RESEARCH: KEYSEARCH

• The opened Bankruptcy folder reveals the bankruptcy
subtopics, one of which is Discharge.

• If Sarah opens the Discharge subfolder and she will find
Educational Loans.

• Sarah selects the All
Federal Cases
(ALLFEDS) database.
• She could click the
View/Edit Full Query
link to see the preformulated query.
• Notice that the query is
a combination of words
and key numbers.

• Sarah could add
additional terms.

• This is one of the
cases retrieved
from the
ALLFEDS
database and it
talks about
discharging
student loans on
the basis of
hardship.
• There is also a
reference to the
discharge statute.

Hardship

11 USCA 523(a)(8)

CONTENTS
• Introduction
• The Legislative Process

• Anatomy of a Statute
• Statutory research: Print and Online
• Updating Statutory Research
• Expanding Statutory Research
– KeyCite®
– Case Law (Annotations)
– Legislative History
– Secondary Sources

UPDATING STATUTORY RESEARCH:
VERIFYING THAT STATUTE IS CURRENT
• Sarah has found the statute and interpreting case
law that says that student loans are not discharged
in bankruptcy.
• She has found cases that state the only exception
is on the basis of undue hardship.
• What if the statute has been recently amended or
repealed or case interpretation of the statute has
changed?

OFFICIAL PRINT UPDATES
• Print updates
– Slip laws are individually printed and sent to all U.S.
government depository libraries.

– The Statutes at Large is the earliest official compilation of
all laws passed at the end of each session of Congress.
• Published in chronological order
• No general index
• Publication lags about two years behind the enactment
of the public laws

PRINT & WESTLAW CURRENCY
• U. S. Code Congressional and Administrative
News (USCCAN) issues monthly pamphlets.
• After each session, the monthly USCCAN
pamphlets are reissued in a bound volume.
• Laws are in the US-PL (United States Public Laws)
database on Westlaw within hours of passage.
• XX-LEGIS is the identifier for the state
session law databases on Westlaw. State laws
go online as soon as they are received by
West.

UPDATING STATUTORY RESEARCH: U.S.
CODE UPDATES
• Always check in the following
print publications to determine
current law:
– Cumulative pocket parts
– Interim pamphlets and statutory
supplements that include the public
law changes to the code and
recent notes of decisions from
cases that have construed the
statute since the last supplement
was published.

KEYCITE ON WESTLAW
Use KeyCite History

to determine whether the statute is good law

KEYCITE ON WESTLAW
This statute has been
declared unconstitutional
or preempted.

• A red flag means that the statute has been
– Recently amended
– Repealed
– Ruled unconstitutional
– Preempted

All or a portion of the statute may no longer be good law.

• Click the red flag or History on the Links for tab to see
that this statute has been held unconstitutional by
several courts.

KEYCITE ON WESTLAW
Both KeyCite History and
Citing References link to
display Pending
Legislation
that might affect statute.

• A yellow flag means that the statute
– Has pending legislation
– Has been renumbered
– Has been transferred

– Contains an editor’s amendment note.

The statute is good law but should be monitored for changes.

• Click the yellow flag on the Links for tab to display this
statute’s Pending Legislation.
• Note that you can link to the pending bills.

KEYCITE HISTORY FOR STATUTES
• Updating documents (recently passed public laws
that have amended or repealed the statute)

• Pending legislation that may affect the statute
• Credits (citations to past public laws that have
enacted, amended or renumbered a statute)
• Historical and statutory notes that describe the
legislative changes that have affected that statute
• Cases that have held that the statute is
unconstitutional

QUESTION
A red flag on a statute can mean that the statute
1.

Has been declared unconstitutional

2.

Has pending legislation

3.

Has been amended

4.

Both 1 and 3

EXPANDING STATUTORY RESEARCH
• KeyCite Citing References

• Case law that has interpreted or applied the statute
– Annotations (Notes of Decisions)

• Legislative history

• Secondary sources
– American Law Reports

– American Jurisprudence 2d

EXPANDING STATUTORY RESEARCH:
KEYCITE CITING REFERENCES

Many USCA sections have many citing references. In the right
frame are some of the 41,791+ citing references to 11 U.S.C.A.
523.

USING KEYCITE
• KeyCite Citing References consists of citations to
legal documents that discuss or mention the statute.

• Citing references include:
–
–
–
–
–

Pending legislation
Notes of Decisions (Annotations)
Cases on Westlaw that do not appear in notes of decisions
Administrative materials (includes agency decisions)
Secondary sources, such as ALR® articles, Am Jur 2d®
sections, law reviews, and treatises
– Briefs

LIMITING KEYCITE CITING REFERENCES

Limit KeyCite Display

• 11 USCA 523 (the Exceptions to Discharge statute)
has 41,791 citing references.
• Click the Limit KeyCite Display button near the
bottom of the screen to limit the citing references to
the ones of most use to you.

• You can limit citation
results by any number or
combination of:
–Notes of Decisions (by
sub-topic)
–Locate terms
–Jurisdiction
–Date
–Document type

• Select the desired
criteria and click Apply.


The original 41,791 citing documents have been reduced to
17 documents that meet the criteria we specified.

NOTES OF DECISIONS
• Many statutes are obscurely worded and must be
interpreted by case law.
• Notes of Decisions (or annotations) are headnotes of
cases that significantly interpret or apply the statute.
• Case law compares the language of the statute with
the language of other statutes, reconciles language
within the statute, and explores legislative history
concerning the statute to discover the intent of the
legislature.
• The language of the case law often becomes more
useful for the researcher than the language of the
statute.

NOTES OF DECISIONS
• Notes of decisions can be accessed by clicking the
Notes of Decisions link on the Links for tab when
viewing a statute.
• Notes of Decisions are preceded by a main index
and, if needed, subdivision indexes.
• Each subdivision deals with one topic of interpretation
of the statute by the courts.

Notes of Decisions

NOD Index

NOTES OF DECISIONS

• Above are the Notes of Decisions for 11 USCA 523 under the
Educational or Student Loan subdivision.
• Note the links to the full-text cases.

NOTES OF DECISIONS IN PRINT
• As in the online Notes of
Decisions, the print
Notes of Decisions are
the last portion of the
annotated statute format.
• The Notes of Decisions
for some statutes may
be hundreds of pages
long.

LEGISLATIVE HISTORY
• Because so many statutes are obscurely worded:
– courts often look to the legislative history of a statute to
determine the intent of the legislators.
– debates in Congress or congressional committees, early
drafts of the bill, testimony of experts, amendments to the
language of the proposed statute, etc., often reveal the intent
of the legislature.

• Committee reports provide the most definitive
evidence of legislative intent.

EARLY LEGISLATIVE HISTORY
• Legislative history may include documents that exist
even before a bill is enacted:
– Presidential recommendations.
– Congressional and committee hearings in sessions in which
the bill was discussed but not passed.
– Agency memoranda.
REMEMBER – Don’t just limit your research only to the
legislative session in which the bill was enacted.

LEGISLATIVE HISTORY IN ANNOTATIONS
• You can access Legislative History directly from the link on the
Links for tab in the left frame. Click Text Amendments, also called
Credits. They are the public laws that created and amended the
statute.

Credits

Public Laws

LEGISLATIVE HISTORY IN ANNOTATIONS
• You can also link to the Editor’s Notes, also called the Historical
and Statutory Notes, that follow each USCA section. Editor’s
Notes give more detailed information regarding the legislative
history of the statute, including House and Senate
Reports, Committee Reports and explanations of the change in
language from one report or public law to the next.

Editor’s Notes

EARLY LEGISLATIVE HISTORY
• Early congressional hearings and testimony can be
found in several databases on Westlaw, including
USTESTIMONY, USPOLTRANS, CQNEWS,
BNA-TRACK and APN-HO.
• Presidential messages can be found in the PRESDAILY, USPOLTRANS, USCCAN, BNAPRSCAL, and CQ-NEWS databases on Westlaw.
• Committee Reports, the most definitive evidence of
legislative intent, can be found in the LH database.

EXPANDING STATUTORY RESEARCH: BILL
DISCUSSION & TESTIMONY
• Discussions/debates regarding a federal bill can be
found in
– the Congressional Record in print and on Westlaw in the CR
database
– United States Code Congressional & Administrative News
(USCCAN) in print and in the USCCAN database on Westlaw

HISTORY OF MODIFICATION TO BILLS
• Language of bills as they are modified in the legislative
process can be found in:
– microfiche in government depositories, including many law
libraries
– materials from the clerk of the legislature
– Congressional Record and USCCAN in print
– CR, USCCAN, CONG-BILLTXT, and LH federal databases on
Westlaw
– XX-BILLTXT (where XX is state’s two-letter postal abbreviation)
databases on Westlaw.

CURRENT STATUS OF A BILL
• The status of a bill can be found in:
– Federal materials
•
•

print status tables
US-BILLTRK (United States Bill Tracking)

– State materials
•

XX-BILLTRK (where XX is the two-letter postal
abbreviation of the state) databases on Westlaw

Bill Referred to Committee

Under Add a
Tab, you can
set up a
Legislative
History Federal tab.

When you click any step in the
legislative process, a search
screen is displayed showing
databases where that material can
be found.
Databases

SECONDARY SOURCES
• Secondary sources are analytical materials that
comment on, explain, and analyze a wide range of
legal topics.
• Secondary-source materials are prepared by legal
experts in a non-litigious context.
• Most contain a detailed discussion of the legal topic.
• Most are carefully researched.
Most include references to relevant
cases and statutes and other
secondary sources.

SECONDARY SOURCES
• The following are some of the secondary sources that
are available in print and on Westlaw that can be used
to expand your statutory research.
• American Law Reports (ALR) – ALR database
• American Jurisprudence (Am Jur 2d) – AMJUR
database
• Law review articles – JLR (Journals and Law
Reviews) database
• Restatements – REST databases

• West’s Digests – -HN is suffix for digest (headnote)
databases, e.g., MN-HN, ALLFEDS-HN

SECONDARY SOURCES
• This is a portion of an ALR
article discussing the legislative
history of 11 USCA 523 in
reference to whether student
loans can be discharged in
bankruptcy.

• The same ALR article
could have been
retrieved using the ALR
link on the Links for tab
while viewing the statute
in the right frame.

ALR

SECONDARY SOURCES

• One of several American Jurisprudence sections that discuss
whether loans can be discharged in bankruptcy. This section
discusses exceptions to the student loan exception of
discharge of debt in bankruptcy.

CONCLUSION
• There are many ways to approach statutory
research. No one method is correct.
• If one method doesn’t seem to be working, try
another.
• Still need help?
• Call the West Reference Attorneys at
1-800-850-WEST (9378)

• They are available 24 hours a day, seven days a
week.

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