short paragraphs at the beginning of a case report that summarize each point of law in the case. Headnotes are added by the publisher, not the court, and should never be cited. Headnotes in West reporters include references to West's topic-and-key-number system, and the headnote paragraphs are reproduced in West digests. West headnotes also appear on Westlaw, and LexisNexis has its own headnote system.