About
Corrections log
This is the Library's single log of substantive corrections and supersessions — the running record the corrections policy promises. Each entry preserves what the record said, what it says now, and when it changed. Entries that were true when written and were overtaken by events are marked superseded rather than corrected; the Library distinguishes error from supersession. Entries run newest first and are numbered from 001 in date order.
Until August 9, 2026 the Library kept two ledgers on two sites, both numbered from 001. They were merged here on that date and the entries were renumbered. Entry 008 records the merge and carries a concordance from the old numbers to the new ones.
2026
045 · October 20, 2026 — yesterday’s correction to Asarco’s holding was keyed to two sentences, and a third sentence saying the same thing survived on three pages
What the record already said. Entry 044 of October 19, 2026 corrected the statement that Asarco Inc. v. Kadish, 490 U.S. 605 (1989), held state statutes inconsistent with the federal-compact Enabling Act framework unconstitutional. The Court held that “the sale or lease of mineral lands granted to the State of Arizona under these federal statutes must substantially conform to the mandatory requirements set out in the Enabling Act” — the statutes being the Enabling Act of 1910 and the Jones Act of 1927 — and held the court below “correct in declaring Ariz. Rev. Stat. Ann. § 27-234(B) (Supp. 1988) invalid as to nonhydrocarbon mineral leases.” 490 U.S. at 633. “Unconstitutional” is the Arizona Supreme Court’s word, which this Court quoted; the Court’s own words for the result are void and invalid.
What the record says. Entry 044 named three surfaces and corrected them, but the strings it asked the checks to watch for were two particular phrasings. A third phrasing of the same overstatement — that Asarco holds state statutes “inconsistent with the federal compact unconstitutional” — stood in the closing sentence of the doctrinal-arc paragraph on the Library’s Asarco entry and on its Vincennes entry, and in the allied-authority sentence of the Conservation Northwest v. Commissioner of Public Lands case file. On the Asarco entry the surviving sentence sat in the same paragraph family as the sentence entry 044 had just added, which says that “unconstitutional” was the state court’s word and not the Supreme Court’s for its own holding. The page contradicted itself.
What changed. All three sentences now state the holding in the Court’s own terms: granted mineral lands must substantially conform to the Enabling Act’s mandatory requirements, and the Court affirmed the state court’s declaration that a nonconforming statute is invalid. Each carries a dated note. One sentence on the Asarco entry is deliberately unchanged: it says that state statutes purporting to authorize departures from the Act’s requirements are inconsistent with the federal compact, which is the holding and claims no label the Court did not use.
Why the checks did not catch it. The drift check tests the strings a log entry quotes. Entry 044 quoted two phrasings of the overstatement, so a third phrasing was never within its scope — the same failure as entry 014 reaching the case file and not the essay, one level further in: not a correction that reaches one page and stops, but a correction that reaches one sentence and stops. The assertions added with this entry are keyed to the proposition on every Asarco surface rather than to a sentence.
044 · October 19, 2026 — correction 014 never reached the essay that paraphrases the case, and two entries stated Asarco’s holding wider than the Court stated it
What the record already said. Entry 014 of August 16, 2026 withdrew the statement that the Supreme Court in Trustees of Vincennes University v. Indiana, 55 U.S. (14 How.) 268 (1852), ordered Indiana to account for the lands and their proceeds. It did not. The Court held the dismissal of the trustees’ bill erroneous, reversed the decree of the Supreme Court of the State of Indiana with costs, and remanded the cause for further proceedings. The word account appears in the opinion of the Court only twice, in the recital of Indiana’s 1820 joint resolution and in the recital of the complainants’ prayer for relief, and never as an order of the Court.
What the record says. The correction reached the Library’s Vincennes case file and stopped there. The Reading Wing essay “Why the Courts Have Mostly Held the Line” carried the withdrawn sentence in ordinary body prose, outside any correction note, for sixty-four days. Separately, the court-lineage entry for Asarco Inc. v. Kadish, 490 U.S. 605 (1989), and the Library’s own Asarco entry each gave the holding as state statutes inconsistent with the federal-compact Enabling Act framework being unconstitutional. The Court held that “the sale or lease of mineral lands granted to the State of Arizona under these federal statutes must substantially conform to the mandatory requirements set out in the Enabling Act” — the statutes being the Enabling Act of 1910 and the Jones Act of 1927 — and held the court below “correct in declaring Ariz. Rev. Stat. Ann. § 27-234(B) (Supp. 1988) invalid as to nonhydrocarbon mineral leases.” 490 U.S. at 633. “Unconstitutional” is the Arizona Supreme Court’s word, which this Court quoted; the Court’s own words for the result are void and invalid.
What changed. The essay now states the disposition and carries a dated correction note. Both Asarco entries now state the holding in the Court’s own terms, with the Jones Act named as the second granting statute and the nonhydrocarbon limitation kept. The statement of the standing holding was already correct and is unchanged.
Why the checks did not catch it. The drift check reads each correction against the pages that correction names. Entry 014 names the Vincennes case file, not the essay, so the essay was never within its scope. This entry names every surface it corrects. This is the failure mode entries 015, 016, 031 and 033 each describe: a correction that reaches one page and stops.
043 · October 16, 2026 — snapshots of the Wisconsin state page kept a word correction 035 retired, and entry 040 quoted the corrected download loosely
What the record already said. Entry 035 of September 29 corrected the Court Atlas’s summary of State ex rel. Owen v. Donald, 160 Wis. 21 (1915): the noun “impress” does not appear in the opinion, which describes the trust lands as “impressed with a special constitutional trust” (at 117).
What the record says. Four frozen snapshots of the Wisconsin state page, which the page renders into itself, still said the case held that dedication created an “impress” of trust, with no correction note. Separately, entry 040 quoted the corrected Clark gloss in the hornbook working-edition download as reading “Sixteenth Section lease consideration measured by the reasonable market value of the land”; the download says Mississippi “benchmarks Sixteenth Section lease consideration to ‘the reasonable market value of the leased land.’” The substance was the same; the quotation was not exact. Both were found by the checks added after correction 042.
What changed. Each of the four Wisconsin snapshots carries a dated correction note beside the retired wording, quoting the opinion at 117 and 119. The snapshot wording itself is preserved as published. Entry 040’s quotation now matches the download word for word, and entry 040 carries a dated note saying so.
042 · October 15, 2026 — a chapter published a dissenting court’s reasoning as the Court’s answer, a second chapter kept a sentence this log retired in September, and a state page served a quotation that is not in the opinion
What the record already said. Three entries in this log had already found these errors. Entry 020 of September 3 corrected, in six places, the attribution of a sentence in Ervien v. United States, 251 U.S. 41 (1919) — that a private proprietor’s wise administration “could not reach the odious dereliction of a breach of trust in the State” — which is the District Court’s reasoning for dismissing the United States’ bill, from a court that was reversed. Entry 020 also recorded that the sentence had been withdrawn from “two live pages — the New Mexico state page, where it was the pull-quote, and the Reading Room essay.” Entry 029 of September 18 corrected Chapter 1, Sec. 1.7, which had given Cooper v. Roberts’s “unalterable except by consent” as a bar on unilateral state modification, and noted that the misreading was “surviving in the hornbook text.”
What the record says. The trust-character chapter, Sec. 3.2, still attributed the Ervien sentence to the Court as its answer to the state’s argument, and still carried the retired Cooper sentence word for word. The New Mexico state page still served both the retired sentence and a second sentence attributed to the Court with “the Court wrote” — “The lands and the moneys which the State received from them are dedicated to specific purposes” — neither of which is in the opinion, three times as a display pull-quote, inside four frozen snapshots of the page that the page renders into itself. The chapter entry 020 described as held back for counsel’s review was not held back; it was republished three times, most recently that morning.
What changed. Sec. 3.2’s Ervien entry now states what the opinion says: the Court conceded the state’s premise, held the Enabling Act’s enumeration exclusive, assigned the odious-dereliction sentence to the District Court, and reduced the statutory phrase to the grantor’s power to impose and enforce conditions, 251 U.S. at 47–48. Sec. 3.2’s Cooper entry now states the compact origin, the vesting rule at *179, and the holding at *181–82 that “it was competent to Michigan to sell the school reservations without the consent of congress,” and no longer presents the case as a limit on state disposition. Both footnotes carry dated notes quoting the retired wording. The New Mexico snapshots carry a dated correction marker at every occurrence, naming the genuine passage at 47. Every citation in this entry was checked against the opinions — Ervien read in full and confirmed against a second independent copy of the official report, Cooper read in full with its star pagination verified by character offset — not against a secondary text or against this log.
What it cost, and what is owed. Forty-two days for the Ervien attribution and the New Mexico quotation, twenty-seven for the Cooper sentence. In each case this log named the surface and then did not go back to it. A correction entry that records a page as held for review is not a fix, and this is the second time in two days that such a note has been found describing a page that was never held — correction 041 found the first. The Library is adding a check that reads this log against the pages it names, and extending the banned-strings gate to the version stores that the state pages render into themselves.
041 · October 14, 2026 — a chapter on the trust character of the grants cited Chief Justice Taney’s dissent as the holding, for a proposition the Court rejected
What the record already said. Correction 014 of August 16, 2026 reported that the sentence the Library had cited most often from Trustees of Vincennes University v. Indiana, 55 U.S. (14 How.) 268 (1852) — lands “granted to the State, as the trustee to administer the trust” — is not the holding but Chief Justice Taney’s dissent. It corrected the Reading Room entry, the Case File annotation and Court Room summary, the doctrinal-lineage entry and the treatise’s working-edition status note, and it named the one page the correction had not reached: “the trust-character chapter repeats the misattribution in its section 3.2 and its footnote 3, with a page citation that lands in the dissent. That chapter is held for review before republication.”
What the record says. The chapter is not held for review. It is published, it is the page a reader lands on, and it has been edited and republished twice since that sentence was written — most recently yesterday, to fix a different citation in the same chapter. Section 3.2 said: “The Court described federal grants of land for educational purposes as creating a trust in which the state holds title as the trustee to administer the trust,” with footnote 3 pinning 55 U.S. (14 How.) 268, 280. Read against the official report: the opinion of the Court is Justice McLean’s, at 271–78, and the phrase appears nowhere in it. It appears once, at 279, in Chief Justice Taney’s dissent — joined by Justices Catron and Daniel, running 278–82 — two sentences after Taney writes that his brethren “have put a different construction on this clause.” Page 280 falls inside the dissent, so the pin was wrong twice: wrong opinion, and a page past the sentence it was given for.
And the proposition is one the Court rejected. This is the part that makes the misattribution more than a credit line. McLean, for the Court, held that title to the school lands “has never been considered as vested in the State; and it has no inherent power to sell them, or appropriate them to any other purpose than for the benefit of schools,” at 274, and that the trust vested in the chartered corporation, “in which the State has no property, and can exercise no power to defeat the trust,” at 277. The Court reversed Indiana and ruled for the university’s trustees. Taney’s was the losing position that the title and the right to administer the trust were the State’s. The chapter cited the dissent for the state-as-trustee framework and called it the framework’s earliest name — which rested the proposition on the one view in the case that did not prevail.
What changed. Section 3.2 now quotes the Court for what the Court held, names Taney’s dissent as the source of the trustee-title sentence, and says plainly that the receiving state as trustee of school lands rests on Cooper v. Roberts (1855) and the cases after it rather than on this one. Footnote 3 pins the majority at 274 and 277, pins the dissent’s phrase at 279, records that the former pin of 280 landed in the dissent, and points to Alabama v. Schmidt, 232 U.S. 168, 174 (1914), where the Supreme Court itself read the case on this ground. Six other Library surfaces — the Reading Room entry, the Case File, the Court Room summary, the lineage entry, the catalog and Chapter 1 — already attributed the sentence correctly and were not touched.
How it was found, and the two things worth keeping. Not from a report. The Library’s own correction log was read against the Library’s own published pages, one entry at a time, the day after that method found correction 017’s closing sentence to be wrong. Entry 014 had disclosed this page in its own text and then been left to go stale, which is the failure 017 named in its own words: a correction log that goes stale is a second error, not a record of the first. Two things follow. A correction that records an uncorrected page needs a date on it, not a condition — “held for review” stops being true the moment the page ships, and nothing in the record notices. And an error can survive a chapter being edited twice, because an edit to note 13 does not re-read note 3.
040 · October 13, 2026 — three of the four errors correction 017 said no reader ever saw were on published Library surfaces, and one of them was live
What the record said. Correction 017 of August 21, 2026 reported four errors caught in unpublished hornbook chapter drafts — a manufactured Kleppe quotation, a Clark v. Stephen D. Lee Foundation gloss, the Kanaly litigation described as two opinions when it is three, and a provenance header crediting a separate writing by Justice Wuest that does not exist. It closed: “None of the four reached a published page.”
What the record says. Three of the four had. The hornbook working edition
offered for download at /drafts/hornbook-working-edition-v1.docx, linked from
the book pages, carried the manufactured Kleppe quotation twice and the
Clark gloss once, in a file built before August 21 and never rebuilt. And the
Kanaly error was not confined to a draft at all: note 13 of
the chapter on the trust character of the
grants described the litigation as producing one further opinion after
Kanaly I, naming Kanaly, 401 N.W.2d 551 (S.D. 1987), and omitting
Kanaly v. State by and through Janklow, 403 N.W.2d 33 (S.D. 1987) (per curiam)
altogether. The Library’s South Dakota appendix, court atlas, case file and catalog
register all carry the third opinion. Only the chapter a reader actually lands on still
said two. The fourth error, the Wuest provenance header, reached nothing: the word does not
appear in the download at all.
What changed. Note 13 now names all three opinions, with the third reported as the appendix reports it — per curiam, no page pin, and its sentence recording that the reimbursement Kanaly I required “has been done” carried with the caution that the court gives no figure, no date and no evidentiary citation for it. The download’s two Kleppe passages now read as the Tenth Circuit wrote: the grants’ “specific purpose was to create a binding permanent trust which would generate financial aid to support the public school systems of the ‘public land’ states.” Its Clark gloss now reads “benchmarks Sixteenth Section lease consideration to ‘the reasonable market value of the leased land,’” which is what the opinion says; the words “fair market value” and the year 1817 appear nowhere in it. The four passages in the same file that quoted Kleppe correctly were left as they were. Entry 017 is amended to record that its closing sentence was wrong, and to point here.
Amended October 16, 2026. The quotation of the corrected Clark gloss above was not word for word; it now quotes the download exactly. See correction 043.
What this cost the Library to learn, and what it did not fix. The download is a hand-built file rather than a build product, so correcting the Kanaly count inside it needs a fresh render rather than an edit; until that render it carries the old count, and that is recorded rather than quietly left. More to the point: the chapter page was being checked nightly for change and reported unchanged every night, which is not the same as being checked for truth. A record that promises readers they can judge the Library’s citations has to be read against the reporters, not watched for drift.
039 · October 8, 2026 — Chapter 4: California’s 1849 Constitution did have a permanent-fund clause
What the chapter said. The chapter on the antebellum doubling said that California’s 1849 Constitution “had a school provision”, that the 1879 Constitution that replaced it “had a thinner one”, and that “[n]either installed a durable irreducible permanent-fund clause comparable to Wisconsin’s Article X § 2 or Oregon’s Article VIII § 2.”
What the record says. The 1849 Constitution contained a permanent-fund clause. The California Supreme Court quoted it in Wyman v. Banvard, 22 Cal. 524, 531 (1863): the proceeds of lands the United States might grant the State for schools “shall be and remain a perpetual fund”, with the interest “inviolably appropriated to the support of common schools, throughout the State.” What California lacked was not the clause but a constitutional trustee board, and a corpus that survived the disposals.
What changed. The chapter now states that the 1849 Constitution had a permanent-fund clause and quotes it from the reporter, and the sentence about the architecture that would have produced a corpus now reads that it was never completed rather than never installed.
038 · October 8, 2026 — Prologue and Chapter 4: Wyman v. Banvard misdated by four years, and read for a holding it does not contain
What the pages said. The Prologue said that the California Supreme Court “would later read the omission as decisive” and that Wyman v. Banvard in 1867 held the school-section grant was not, in the technical legal sense, a trust — a grant the State could dispose of as it pleased. Two Eighth Anchor essays carried the same account.
What the opinion says. The case is Wyman v. Banvard, 22 Cal. 524 (1863) — four years earlier than the pages said. “Absolute and unconditional grant” is genuinely the court’s phrase, at 529. But the opinion does not discuss the omission of in-trust language at all, and in the same passage it holds that “[n]either the lands nor the proceeds thereof can be used for any other purpose” — which contradicts, rather than supports, the account of a grant the State was free to dispose of as it pleased.
What changed. The Prologue now reads: “In Wyman v. Banvard in 1863, the California Supreme Court called the school-section grant an ‘absolute and unconditional grant,’ without discussing the omission, and held in the same passage that ‘[n]either the lands nor the proceeds thereof can be used for any other purpose.’” Chapter 4 and the two essays were conformed to the same reading, with the year and the pin corrected.
037 · October 8, 2026 — Chapter 4, the Volume I conclusion and three essays: Sherman v. Buick is not a trust case
What the pages said. Chapter 4 said that “[t]he case that fixed the doctrine for California’s school grant was Sherman v. Buick, 93 U.S. 209 (1876)”, that the U.S. Supreme Court “read the 1853 Survey Act’s omission of in-trust language as decisive”, and that Sherman is “the doctrinal floor on which every California school-grant case since has been decided.” The Volume I conclusion called the omission “the omission the U.S. Supreme Court would later read as decisive in Sherman v. Buick (1876)”, and The Sacred Compact and The Drift carried the same account.
What the opinion says. Sherman v. Buick never uses the word “trust”. It is a settler’s case: a holder of a federal patent founded on a pre-emption claim against a holder of a state patent to part of a section thirty-six. The Court reversed the California Supreme Court, 45 Cal. 656 (1873), and called the argument about the grant’s character “immaterial to the issue”, 93 U.S. at 215. Neither opinion mentions a trust.
What changed. Chapter 4 now opens the discussion with what the case actually decided and states plainly that it is not a trust case; its footnote now pins 93 U.S. 209, 215–16 (1876) and records that neither opinion uses the word. The attribution was removed from the Volume I conclusion. The Sacred Compact and The Drift now say that Wyman v. Banvard (1863) did not read the omission as decisive and did not discuss it, and that Sherman did not read it as decisive either. In The Coming Trusts, the drafting failure dated to California in 1850 was corrected to 1853, the year of the Survey Act. The Wisconsin half of this same misdescription was corrected on September 29 and is entry 035.
036 · October 8, 2026 — Chapter 4: the Youngstown Mines royalties were not mistakenly paid
What the chapter said. The chapter said that in Youngstown Mines Corp. v. Prout, 266 Minn. 450, 124 N.W.2d 328 (1963), royalties “had been mistakenly paid to the state under a lakebed mineral lease and credited to the school trust fund.”
What the opinion says. The payments were made knowingly, at 266 Minn. 489. The refund rested on the branch of the refund statute addressed to money the State was not entitled to retain, not on error. The rest of the paragraph is supported.
What changed. The sentence now reads: “Royalties had been paid to the state under a lakebed mineral lease and credited to the school trust fund.” The note pins 266 Minn. 450, 479–80, 124 N.W.2d 328, 345–46 (1963).
035 · September 29, 2026 — Court Atlas, Wisconsin: a word the court did not use, and an extension it did not make
What the page said. The Wisconsin page of the Court Atlas summarized State ex rel. Owen v. Donald, 160 Wis. 21 (1915), as having “[e]xtended Sweet to a reforestation and water-power scheme”, and said that under it “constitutional dedication creates an ‘impress’ of trust the legislature cannot ignore.”
What the opinion says. The noun “impress” does not appear in the opinion. The court described the trust lands as “impressed with a special constitutional trust” (at 117). It applied State ex rel. Sweet v. Cunningham, 88 Wis. 81 (1894), to the lands the United States granted for schools: the legislature “cannot devote the same to parks or forests or any purpose inconsistent with the constitutional mandate” (at 95). For the larger body of swamp-grant lands set apart for schools, it held that the commissioners “have only such power as the legislature may see fit to delegate to them” (at 119), subject to the constitutional duty to manage those lands to produce money for the school fund (at 154).
What changed. The Court Atlas entry now states the holding for both classes of land and quotes the court’s own words. The Wisconsin appendix, published the same day, sets out the case.
034 · September 28, 2026 — Chapter 2, § 1.4: the two-section generation dated two years late
What the chapter said. Section 1.4 of the chapter on the granting instruments was headed “The two-section generation, 1859–1906” and opened with Oregon’s 1859 admission act, as though the doubled grant of sections 16 and 36 to a new state began there.
What the opinion says. In Murtaugh v. Chicago, Milwaukee & St. Paul Ry. Co., 102 Minn. 52, 54 (1907), the Minnesota Supreme Court describes section 5 of the Act of February 26, 1857 as granting Minnesota “sections 16 and 36 of the public lands in every township within the state for the use of schools”. That is two years before Oregon’s act. The same passage describes a territorial reservation of both sections in 1849.
What changed. The heading now reads 1857–1906, and a Minnesota entry opens the section, citing the court’s description of the 1849 reservation and the 1857 grant. Neither act is held in the Library’s collection. The entry carries a [VERIFY] flag for their text, and for whether any earlier admission-era instrument granted both sections. The Minnesota appendix, published the same day, sets out the case.
033 · September 22, 2026 — Corrections reached the Library’s prose and never reached the data files its pages are generated from
Where this one was found. The Library’s Court Atlas is built from two sources: long-form dossiers written in prose, and short state summaries and Holding cards generated from two internal data files. Corrections 021 (September 6) and 023 (September 10) rewrote the prose for Oklahoma and South Dakota. Neither reached the data files. The Oklahoma and South Dakota state summaries were live and wrong on the Court Atlas index page for sixteen and twelve days after the corrections that withdrew them. The case cards were not rendering, and this correction says so plainly rather than overstating the exposure: on a state page the generated cards are replaced by the long-form dossier where one exists, and both these states have one. The cards publish for any state without a dossier — today New Mexico and Oregon — so what stood between the withdrawn text and a reader was the presence of a dossier, not the correction. They are also the Library’s structured statement of what these cases hold, and they are corrected here for that reason.
Oklahoma. The state summary, live on the atlas index, called Oklahoma Education Association, Inc. v. Nigh, 642 P.2d 230 (Okla. 1982), “the anti-diversion precedent.” The unrendered card read: “The Legislature cannot divert school trust revenues to non-school purposes consistent with the trust obligation,” and called the case “Oklahoma’s anti-diversion ruling.” Correction 021 had already withdrawn that description. Nigh struck down five statutes that capped the rent the Commissioners of the Land Office could charge on preference-right leases, capped the interest on farm loans and land-sale contracts, and let a sitting lessee renew without matching competing bids. The vice was a subsidy, not a diversion of money already collected: “Just as a State may not use school land trust funds assets to subsidize its highway construction program, a State may not use school land trust assets to subsidize farming and ranching,” 642 P.2d at 236. The court issued no injunction and ordered nothing restored; its decision “will operate prospectively from the date this opinion becomes final,” at 239. Oklahoma’s revenue-diversion authority is a different and earlier case, State ex rel. Williamson v. Commissioners of the Land Office, 301 P.2d 655 (Okla. 1956), which the atlas prose already carried. The cards and the summary have been rebuilt from the opinion.
South Dakota. The card for Kanaly v. State by and through Janklow, 368 N.W.2d 819 (S.D. 1985), gave as its holding: “The school-land grant and its acceptance constitute an irrevocable compact, a solemn agreement, and a contract between the receiving state and the United States.” Correction 023 had withdrawn exactly that, and the state summary — this one live on the atlas index — repeated it. The opinion reports those three descriptions rather than adopting them — “Other courts have also recognized the trust relationship … Such a procedure has been said to create an ‘irrevocable compact,’ … a ‘solemn agreement,’ … and a ‘contract,’” at 823 — each with its own citation to a different court. In its own voice, in the next sentence, the South Dakota court uses two of the nouns and not the adjectives: “this trust, compact, and contract,” at 823–24. “Irrevocable” and “solemn agreement” appear nowhere in the court’s own voice. The state summary compounded the error by calling the three cases “the SCOTUS authorities”: only Andrus v. Utah is a decision of the Supreme Court of the United States. The card now gives what the case actually holds — the “special, permanent and perpetual trust” at 823 and the invalidation of S.B. 221 at 829 — and records that the remedy was a declaration and a deadline, not a decree.
Ervien, on two more surfaces. Correction 020 (September 3) established that the much-quoted line about “the odious dereliction of a breach of trust in the State,” Ervien v. United States, 251 U.S. 41, 48 (1919), is the District Court’s reasoning for dismissing the government’s bill, recited by the Supreme Court and not adopted — and that the District Court was reversed. Two pages still had it wrong in different ways. The Library’s catalog entry said the phrase is “the Court recounting the District Court’s view while affirming its result.” The Supreme Court affirmed the Circuit Court of Appeals, which had reversed the District Court. The Library’s reading-room entry for the case went further and published the phrase as the holding: “Ervien holds that such reasoning, however sincere, is ‘odious dereliction’ of the trustee’s duty.” It is not the Court’s phrase, and its sense is inverted: the District Court used it to say there was no breach. Both pages now carry the Court’s own answer at 48 — that the breach-of-trust language “means no more in the present case than that the United States, being the grantor of the lands, could impose conditions upon their use, and have the right to exact the performance of the conditions.”
A court that did not exist. The same reading-room entry said “the Tenth Circuit reversed.” New Mexico sat in the Eighth Circuit in 1917 and the Tenth Circuit was not created until 1929; the decision below is United States v. Ervien, 246 F. 277 (8th Cir. 1917), which the Library’s own essay footnote cites correctly. The opinion names only “the Circuit Court of Appeals.” The error is carried in the Library’s archival copy of the opinion, in a curator’s header that contradicts itself — one line says Eighth, two say Tenth — and it is recorded for repair there.
A changelog entry left standing, with its error marked. The librarians’ changelog for May 25, 2026 described Asplund v. Hannett (N.M. 1926) as “the early-twentieth-century foundational authority for beneficiary-aligned standing.” Correction 020 established that the case holds the opposite. A changelog is a dated record of what was dispatched, so the entry is left as written and a correction note is set beside it rather than the history being rewritten.
What this one is about. Correction 031 found that a correction filed against a case entry does not reach the pages that paraphrase the case. Correction 032 found that it does not reliably reach the rest of the same page. This one finds that it does not reach the data files a page is generated from — a surface no correction in this log had ever swept. The Library’s internal authorities register had the right answer for all three cases the whole time; the prose pages had it; the generated layer underneath them did not. Two further notes are owed. The first is that the exposure here was smaller than it first appeared, and checking the rendered pages rather than the source is what established that — a check this log now requires before any claim about what readers saw. The second is that a defect which does not render is still a defect: it is what the Library would say if the page above it were removed. Every sweep from here forward runs against generated data as well as prose.
032 · September 21, 2026 — The same two misreadings, still live on the essay pages that paraphrase the cases
Why this entry exists. Entry 031 recorded that a correction filed against a case entry does not reach the pages that paraphrase that case, and said those pages would have to be swept by phrase. That sweep has now been run across the Library’s essay, lineage and reading-room collections. It found both of the misreadings corrected earlier this month still standing on the essay Why the Courts Have Mostly Held the Line — one of them four paragraphs below the correction notice that withdrew it.
A page contradicting its own correction notice. On September 20 that essay was corrected to state that the sentence Congress “imposed upon the State a binding and perpetual obligation to use the granted lands for the support of public education” is Justice Powell’s, dissenting, at 446 U.S. 523, and is not a holding of the Court. Further down the same page, the discussion of the duty of permanence still read: “Andrus characterized the obligation as ‘binding and perpetual.’” The correction had reached the paragraph that discusses the case and stopped there. Read against the opinion, the majority (Stevens, J.) makes no statement of perpetuity in its own voice at all; the word trust does not appear in the majority opinion. The passage now rests the duty of permanence on Kanaly v. State by and through Janklow, 368 N.W.2d 819, 823 (S.D. 1985), which does describe a “special, permanent and perpetual trust” in the South Dakota court’s own voice, and on the granting instruments, which set no term.
And the withdrawn Cooper holding, republished a third time. Entries 028 and 029 withdrew, from the Library’s Cooper v. Roberts entry, the Michigan state page and chapter 1 of the hornbook, the reading that the case limits a state’s power to dispose of school land. The same essay still carried it: the Court, it said, “referred to the grant as carrying ‘the unalterable condition’ that section sixteen of every township be held for the use of schools,” and therefore “the trustee could administer the trust but could not redefine it.” Three things are wrong. The condition is a condition of admission — Michigan “was admitted to the Union, with the unalterable condition” that section No. 16 “shall be granted to the State for the use of schools,” 59 U.S. (18 How.) at *179. The opinion says granted to, not held for. And the conclusion is contradicted by the one point the case decided, at *182: the power of the State is “plenary and exclusive,” the grant runs “to the State directly, without limitation of its power, though there is a sacred obligation imposed on its public faith,” and “it was competent to Michigan to sell the school reservations without the consent of congress.” The paragraph is rebuilt from the opinion and carries its own dated correction note.
A third page, milder but unqualified. The reading-room entry for Elizabeth Marsh’s 2007 Enabling Acts and the Power of You listed, among the authorities Marsh collects, “Andrus v. Utah (446 U.S. 500, 1980) on the binding and perpetual obligation Congress imposed.” Marsh does cite the case; the entry did not say that the formulation is the dissent’s. It now does.
Essay 6, released September 23, 2026. The essay The Beneficiaries Who Cannot Speak formerly carried both misreadings in a single sentence — “Andrus speaks of a ‘binding and perpetual obligation’… Cooper v. Roberts refers to the grant as carrying ‘the unalterable condition’ of trust for schools” — and, a paragraph earlier, stated that “Andrus and Kanaly are explicit” that the trust is “perpetual, not generational.” Neither opinion says so: the Andrus majority is silent on perpetuity, and Kanaly uses no generational language at all, distinguishing instead between “[a] perpetual trust fund for school purposes” and “a perpetual school,” 368 N.W.2d at 824. The page was cleared for release on September 23, 2026. The three overreads are corrected on the essay itself; the Oregon litigation narrative is unchanged.
The register entry the annotation had already refuted. The Library’s internal authorities register summarised Cooper as holding that the “[s]ection-16 grant is a compact ‘unalterable except by consent’” — a summary its own verification note, added September 18, spends a paragraph refuting. The quoted words describe the articles of the Ordinance of 1787, at *177, not the section-sixteen grant. The summary line has been corrected to match the annotation beneath it.
031 · September 20, 2026 — Andrus v. Utah: a four-Justice dissent published as a holding on five pages, and a district court’s sentence attributed to the Supreme Court
What the pages said. Five Library pages stated, in one form or another, that Andrus v. Utah, 446 U.S. 500 (1980), had characterized the federal school grant as a “solemn agreement” creating a “binding and perpetual obligation.” The essay Why the Courts Have Mostly Held the Line put it most directly: “The Court reaffirmed that Congress had imposed on the states a ‘binding and perpetual obligation’ to use the granted lands and their proceeds for public education,” and drew from it the conclusion that the perpetual character of the obligation is what Andrus contributes to the doctrine. The same pairing appeared in the court-lineage entry for Asarco v. Kadish, in the reading-room entries for Trustees of Vincennes University v. Indiana and Asarco, and in the shorthand “the obligation is perpetual (Andrus)” used on two of those pages. A sixth page, How the Trust Was Broken, said that the U.S. Supreme Court, in Lassen, Andrus and ASARCO, “has affirmed and reaffirmed that the school land grants are ‘in the nature of a bilateral compact entered into between two sovereigns.’”
What the opinion says. The sentence “Congress also imposed upon the State a binding and perpetual obligation to use the granted lands for the support of public education” appears at 446 U.S. 523, under the running head Powell, J., dissenting. It is Justice Powell’s, joined by Chief Justice Burger and Justices Blackmun and Rehnquist — four Justices in dissent, not the Court. The majority (Stevens, J.) ruled for the Secretary of the Interior, against Utah, at 502. What the majority does say about the character of the grant it says by adopting the State’s own characterization: “As Utah correctly emphasizes, the school land grant was a ‘solemn agreement’ which in some ways may be analogized to a contract between private parties,” at 507, with the indemnity right existing “to give the State the benefit of the bargain,” at 508. The words “bilateral compact” appear in the case only in Powell’s dissent; the sentence about a compact “entered into between two sovereigns” is not in it at all. That sentence belongs to a federal district court, in State of Utah v. Andrus, 486 F. Supp. 995, 1001 (D. Utah 1979).
What was corrected. All six pages now state the majority’s framing with the attribution the Court itself gives it, and identify the perpetual-obligation sentence as the dissent’s, with its page. The bilateral-compact sentence is returned to the district court that wrote it. Where a page had built an argument on the dissent — that permanence is Andrus’s doctrinal contribution — the argument is restated on what the grants themselves provide, which set no term, rather than on this case. Separately, § 1.8 of Chapter 2 described the holding as reached “within a framing that treated the underlying grant as a solemn agreement,” stating in the treatise’s own voice, unquoted and unattributed, the characterization the Court expressly attributes to Utah — while § 1.7 of the same chapter had it right. That section now matches, and its footnote, which carried no page pin at all, carries three.
How this happened, which is the part worth recording. The majority/dissent confusion in this case was found and corrected on September 11, 2026, in the chapter footnotes and in the Library’s case entry for Andrus. It was not corrected on the essay, lineage and reading-room pages that paraphrase the case, because those pages were never swept — a correction filed to a case entry does not reach the pages that discuss it. Pages that paraphrase an authority have to be swept by phrase, not by case file. All pins in this entry were read in the official United States Reports, from the Library of Congress page images of volume 446, which carry true folio numbers.
030 · September 19, 2026 — Pollard’s Lessee v. Hagan: a quotation cut short, and a case cited for a proposition it declines
What the entry said. The reading-room entry for Pollard’s Lessee v. Hagan, 44 U.S. (3 How.) 212 (1845) quoted the Court as holding that to deny Alabama the sovereignty Georgia had held “is to deny that Alabama has been admitted into the union on an equal footing with the original states.” It gave no page pin. The entry also named the case as the doctrinal anchor for the Library’s argument that admission-act conditions are “real, binding bilateral compacts — not gifts the state may unilaterally modify after admission, and not impositions the federal government may unilaterally rescind.”
What the reporter says. The sentence does not end where the entry ended it. At 44 U.S. (3 How.) 228-29 it runs on: “… on an equal footing with the original states, the constitution, laws, and compact, to the contrary notwithstanding.” The entry had dropped the closing clause and closed the shortened sentence with a full stop and no ellipsis. On the second point the opinion runs against the proposition it was cited for: had “an express stipulation … been inserted in the agreement, granting the municipal right of sovereignty and eminent domain to the United States, such stipulation would have been void and inoperative,” 44 U.S. (3 How.) at 223. In Pollard’s Lessee equal footing overrides a contrary term in the admission compact; it does not enforce one.
What changed. The quotation is restored in full with its pin. The “Why the Library cites it” section now states the equal-footing holding the case does supply and the limit it places on compact terms, and no longer presents the decision as authority for the binding force of admission conditions. Both passages were checked word by word against the bound reporter — the Library of Congress scan of volume 44 of the United States Reports — not against a secondary text. The opinion’s attribution to Justice John McKinley, which the entry already carried, was checked at the same time and is correct.
029 · September 18, 2026 — Chapter 2, § 1.7: a real quotation from Cooper v. Roberts, attached to the wrong proposition
What the chapter said. The first corollary of § 1.7 (“the terms bind both sovereigns”) read that “the Supreme Court has treated the school-grant compacts as ‘unalterable except by consent’ of both parties, so that a state legislature cannot unilaterally modify the framework its state accepted at admission,” citing Cooper v. Roberts, 59 U.S. (18 How.) 173 (1855), without a page pin.
What the opinion says. The quoted words are genuine — unlike the two sentences corrected in entry 028, they do occur in the opinion. But they occur at *177, where the Court is describing the articles of the Ordinance of 1787, “which settled terms of compact between the people and States of the northwestern territory, and the original States, unalterable except by consent.” That is the Ordinance’s own unalterability clause, not a statement about the section-sixteen grant to an admitted State. The unalterability Cooper attaches to Michigan is different and narrower: Michigan was admitted “with the unalterable condition” that section sixteen be granted for the use of schools (*179).
And the consequence ran the other way. The clause the chapter drew from the quotation — that a legislature cannot unilaterally modify the framework — is contradicted by Cooper itself at *181-82, on the one point the case decided. The Court held that the trusts created by these compacts “relate to a subject certainly of universal interest, but of municipal concern, over which the power of the State is plenary and exclusive,” that the grant “is to the State directly, without limitation of its power, though there is a sacred obligation imposed on its public faith,” and that “it was competent to Michigan to sell the school reservations without the consent of congress.” This is the same misreading corrected on the reading-room and state pages in entry 028, surviving in the hornbook text.
A contradiction inside one chapter. The chapter’s own discussion of Papasan’s footnote 18, at § 1.1, already collected Cooper on the other side — against a binding trust in the early grants, quoting the same *181-82 sentence. § 1.7 and § 1.1 were stating opposite things about the same case. § 1.7 now states what the opinion holds, carries the three pins, and notes that the narrower no-unilateral-amendment proposition rests on the accepting instruments and the state authority collected in the same section, not on Cooper.
The corresponding passage in the trust-character chapter carries the same error and is not corrected here; that chapter is held for counsel review, and the correction is recorded in the Library’s internal verification log pending release.
028 · September 17, 2026 — The Cooper v. Roberts pages: a wrong Justice, two quotations that are not in the opinion, and a holding stated backwards
The wrong Justice. The Library’s reading-room entry for Cooper v. Roberts, 59 U.S. (18 How.) 173 (1855), named Justice John Catron as the author of the opinion, and the Michigan state page said the same. The opinion of the Court was delivered by Justice John A. Campbell. Both pages now say so.
Two quotations that do not exist. The entry introduced two passages as coming “from Justice Catron’s opinion.” Neither is in it. The sentence “The State has accepted these benefits, and is bound to administer the trust with fidelity” appears nowhere in the opinion — the word fidelity does not occur in it at all — and the sentence beginning “The sixteenth section was set apart by Congress” is not there either; the opinion says “section No. 16” throughout. The lead-in “We agree with the Supreme Court of Michigan that” was attached to the “sacred obligation” clause, which the opinion states without it. The quoted passages on the entry are now the reporter’s, printed as three later Supreme Court opinions held in this collection print them.
And the holding ran the other way. The entry said the Court held “that the trust purpose constrained the state’s authority to dispose of the land,” and the Michigan page said the Court “declared that such grants are not ordinary state property but a trust.” In the same passage that supplies the famous phrase, at *181–82, the Court said the power of the State over the subject is “plenary and exclusive,” that the grant is “to the State directly, without limitation of its power, though there is a sacred obligation imposed on its public faith,” and that “it was competent to Michigan to sell the school reservations without the consent of congress.” Papasan v. Allain, 478 U.S. 265, 279–80 (1986), reads the case the same way, and collects it among the authorities cited for the fee-simple reading. The Court Room case file carried a second version of the error — that the grant “vested in the state of Michigan at the moment of admission” — when the opinion holds that title ripens when the survey designates the section, the reading the Court confirmed in Beecher v. Wetherby, 95 U.S. 517, 524 (1877). The Court Room page also had the parties reversed: the party holding under Michigan’s patent was the plaintiff, not the holder of the adverse mineral claim.
Two claims about how often the case is cited have been withdrawn. The case file said Cooper’s “unalterable condition” phrase is “language quoted by every subsequent school-trust-lands opinion in the SCOTUS line” and is cited by Lassen, Andrus, Branson and County of Skamania. Nothing held in this collection supports either statement: of the opinions held here only Beecher uses the phrase, and of its own admission clause; Lassen v. Arizona, 385 U.S. 458 (1967), which the Library holds in full, does not cite Cooper at all. The list of state supreme courts said to cite the case for a state-as-trustee proposition now carries a [VERIFY] flag rather than standing as fact.
A note on the year, and on a pattern. Cooper was decided at the December Term 1855 and entered as filed January 29, 1856. The Library cites it as (1855), after the term; the Supreme Court cites it as (1856). Both name the same case, and the reading-room entry now says so rather than leaving readers to reconcile the two. This is the third case page in six weeks found to name the wrong Justice — see entry 014 (Vincennes, August 16) and entry 025 (Andrus, September 11). The pages were written before the Library held the full opinions; each is being corrected as the opinion is read whole against it.
027 · September 16, 2026 — Bob Zybach identifies “beef ranch” in the conversation
In paragraph 24 of the September 13 conversation, the machine transcript rendered “beef ranch” as “deep grant.” The Library had marked the phrase unclear. Bob identified the words as “beef ranch” on September 16. The conversation and the same passage quoted in How a Collection Comes In now carry his correction, with dated source notes. This records the speaker’s clarification; no new check of the audio is claimed. The original transcript is preserved, and the omitted passages, withheld names and audio-publication limits are unchanged.
026 · September 14, 2026 — Bob Zybach corrects the Knauf names and clarifies a recollection
In the September 13 conversation, the machine transcript rendered Wayne Knauf’s surname as “Knopp,” and the Library had left his brother’s nickname unconfirmed. Bob supplied the names Wayne Knauf and Eldon “Tope” Knauf on September 14. The surname is corrected in the transcript and an omission explanation; a dated note identifies Eldon without inserting his given name into the recorded speech. The correction table records the source of the change.
Bob also said Charlie Olson was born “probably 1898,” recalling the 1890s from memory. Dated editorial notes in the booklet and the conversation now record that qualified clarification alongside the collection’s 1898 date. His spoken “1890” remains visible; his reply is not presented as independent verification. The unresolved words “deep grant” remain marked unclear. September 16 addendum: Bob has since identified the words as “beef ranch”; see entry 027.
The conversation’s search description also said nine passages had been omitted, while the reviewed edition and visible page said twelve. The description now says twelve. This corrects the description only; the omissions and withheld names are unchanged.
025 · September 11, 2026 — The Andrus case page: a wrong Justice, a wrong land grant, and a remedy pointed at the wrong party
Four errors of fact. The Library’s reading-room page for Andrus v. Utah, 446 U.S. 500 (1980), named Justice Stewart as a member of the Powell dissent. He was not: that dissent was joined by the Chief Justice and Justices Blackmun and Rehnquist. The page said Utah’s grant ran to “sections sixteen and thirty-six”; the Utah Enabling Act of 1894 granted four numbered sections — two, sixteen, thirty-two and thirty-six. It pinned the Powell passage at 522-23; the three sentences it quotes run 523-24. And it pinned footnote 1 of Cascadia Wildlands v. Department of State Lands, 365 Or 750 (2019), at 752; it is at 753.
And the bargain pointed the wrong way. The page said the grant conferred “on the beneficiaries the ‘benefit of the bargain,’” and built on that a claim that the phrase “supplies the substantive measure of what the trustee owes.” The Court’s sentence, at 508, is about the other side of the compact: “the purpose of the right to make indemnity selections was to give the State the benefit of the bargain.” That right is the state’s remedy against the United States for failing to convey the designated sections. The opinion does not reach what a state owes its schools. Both passages are rewritten.
Two claims the Library cannot support are now flagged rather than asserted. The page said the “solemn agreement” framing “has been adopted by the supreme courts of Utah, Montana, Idaho, Wyoming, South Dakota, Nebraska, Oklahoma, and Arizona.” The Library’s own state appendices record no such adoption for any of the eight, and for South Dakota they record the opposite — Kanaly reports the descriptor rather than adopting it. The page also called the Powell passage the most-quoted in the field, in three places; that superlative was withdrawn from the Library’s internal register on August 1, 2026 and should have come off this page then. Both now carry a flag naming what would have to be done to establish them.
The same case, on the Court Room page. The Library’s case file for Andrus repeated the four-section error and named the wrong statute — the Secretary acted under section 7 of the Taylor Grazing Act of 1934 as amended in 1936, not the Federal Land Policy and Management Act of 1976. More seriously, under a heading reading “Holding,” it told readers that the Court “reaffirmed that Congress had imposed on the states a ‘binding and perpetual obligation.’” That phrase is Justice Powell’s, in dissent, at 523; the word “perpetual” does not appear in the majority opinion at all. The page now says whose words they are, and records that the Court reversed the Tenth Circuit and that Utah lost.
024 · September 11, 2026 — A Supreme Court sentence published backwards, and a South Dakota attribution left half-corrected
The benefit ran the other way. A footnote in Chapter 2 of the legal reference manual told readers that the majority in Andrus v. Utah, 446 U.S. 500 (1980), characterized the school-land grant as a “solemn agreement” producing a “benefit of the bargain” obligation on the state. The Court’s sentence runs the other way. At 508 it reasons that the State’s right to make indemnity selections exists “to give the State the benefit of the bargain” — the benefit is the State’s remedy for the Federal Government’s failure to convey the designated sections, not a burden the grant places on the State. The chapter had it right six sections later, so it contradicted itself. The footnote now states what the Court said and records what it used to say.
And the Court was endorsing, not coining. The phrase “solemn agreement” is not the Court’s own. At 507 the opinion reads: “As Utah correctly emphasizes, the school land grant was a ‘solemn agreement’ which in some ways may be analogized to a contract between private parties.” The Court endorses a characterization it attributes to a party and keeps in quotation marks. The footnote and the passage six sections on now say so.
The South Dakota descriptors, in Chapter 2 this time. Entry 023 corrected a court-atlas entry that presented an “irrevocable compact,” a “solemn agreement” and a “contract” as what the school-land grant is, when Kanaly v. State by and through Janklow, 368 N.W.2d 819 (S.D. 1985), reports those descriptions rather than adopting them. A footnote in Chapter 2 carried the same reading and was missed; a second cited Kanaly for the proposition without characterizing it. Both now record that at 823 the court writes only that “[s]uch a procedure has been said to create” them — the subject being federal enabling legislation plus state acceptance, not the grant — and that what the court does adopt, in its own voice at 823-24, is “this trust, compact, and contract created and established by the Enabling Act and the South Dakota Constitution.”
And a page number off by one. Two footnotes placed footnote 1 of Cascadia Wildlands v. Department of State Lands, 365 Or 750 (2019), at page 752. It is at 753. Both are corrected. The Library’s copy of that opinion carries a running page head on every page, so this was checkable all along and should have been checked when the pin was written.
023 · September 10, 2026 — A South Dakota remedy the court never ordered, published on three pages as one it granted
A declaration published as a decree. Three pages — the Library’s case file for Kanaly v. State by and through Janklow, 368 N.W.2d 819 (S.D. 1985), its South Dakota court-atlas entry and its South Dakota state page — told readers that the South Dakota Supreme Court had ordered the trust made whole. The case file carried the heading “The restoration remedy is operative” and said the court “required reimbursement”; the state page said Kanaly “ordered the state to reimburse the trust the full market value of what was transferred.”
The court ordered nothing of the kind. It declared the uncompensated transfer unconstitutional, held that “the legislature will have to reimburse the trust fund” (824), and then left the correction where it found it: “Whether this should be done through an appropriation or other additional legislation is a determination for the legislature” (824). No injunction issued and no money judgment was entered. The remand went only to valuing the property (829), and the sole lever was a deadline (825). Two years later the same court said that remand “did not make the educational fund a trust administered through the court. . . . It remained a trust under the control and management of the legislature.” Kanaly v. State ex rel. Janklow, 401 N.W.2d 551, 554 (S.D. 1987). The three pages now say what the opinions say.
Three further statements corrected on the same pages. The court-atlas entry said Kanaly “synthesized federal and sister-state precedent into one of the strongest national statements of the perpetual-trust doctrine.” In its own voice the opinion cites five authorities from outside South Dakota against more than twenty of its own, four of the five in a single paragraph. The same entry presented an “irrevocable compact,” a “solemn agreement” and a “contract” as what the grant is; the opinion attributes all three descriptions to other courts and says such an arrangement “has been said to create” them, adopting only the nouns compact and contract in its own voice. And both the case file and the state page said a 1985 statute moving the school’s trust land had been “sustained” in Merkwan v. State by and through Janklow, a decision the Library does not hold; what the Library can verify is that the statute preceded Kanaly and that the court said it “obviated any need for plaintiffs’ requested relief.”
A quotation withdrawn from an internal record. The Library’s internal authorities register recorded the 1987 fee decision as holding the school trust “managed by the legislature,” in quotation marks, as the court’s words. The phrase is not in the opinion; the court wrote “It remained a trust under the control and management of the legislature” (554). The register has been corrected. No public page carried the fabricated form, and the treatise chapters use the same words without quotation marks, as the Library’s own paraphrase, which is accurate.
Smaller corrections in the same pass. A page citation in the case file was moved from 824 to 825, where the sentence actually sits. The state page had attributed South Dakota’s ten-dollar-an-acre minimum to the federal Enabling Act; the Act as the Library holds it quoted requires full market value and states no figure, and the minimum was South Dakota’s own constitutional addition. That page also placed the state’s first trustee decision “within six years” of statehood (it is seven), quoted Article VIII, § 7 in a shortened form that is the 1985 opinion’s summary rather than the constitutional text, and described a “130-year unbroken line” of decisions. The court-atlas entry described the Enabling Act as requiring appraisal and barring sales below appraised value; the section the Library holds quoted requires full market value, which is the stronger standard. On the Oklahoma appendix, one cross-reference sent readers to Chapter 4 for constitutional reception, which is Chapter 3.
The errors were found by the Library’s standing verification program reading the three Kanaly opinions and the Washington Supreme Court’s Conservation Northwest opinion in full against every South Dakota statement the Library publishes. The full record, including the pin cautions that go with copies missing their reporter pagination, is in Appendix A — South Dakota, published with this correction. One divergence is recorded rather than resolved: the court-atlas entry grades South Dakota “under review” while the state page records the verdict “Kept faith.” Both are the Library’s own voice and they cannot both be its position.
022 · September 8, 2026 — The Library’s federal tax status was described as filed when no application had been filed
Three pages — About, Building This Library and the organizational record — stated that the Library’s application for recognition of federal tax exemption had been filed. It had not. One of the four sentences went further and described the Internal Revenue Service as acting on a filed application.
No application had been filed at any time before September 8, 2026. The Library’s Articles of Incorporation were e-filed on July 21, 2026 and its Employer Identification Number was issued on July 30, 2026; the federal application was in preparation and was not submitted.
The sentences have been replaced with: “The Library has not yet filed its application for federal tax-exempt recognition; it is being prepared. No federal tax-exemption determination has been issued, and until one is, the Library does not describe contributions as tax-deductible.”
The error was found by the Library’s own review of its published statements against its corporate record. The Library’s contribute page carried the correct limitation throughout, and at no time did the Library describe contributions as tax-deductible or describe itself as a section 501(c)(3) organization.
Addendum, September 10, 2026. The sentences were replaced on the evening of September 7, 2026 (Pacific time), in the same change that published this entry; the entry carries the date September 8, 2026. The board ratified the correction by written consent on September 10, 2026 and asked that the ledger also record when each sentence first appeared; those dates will be added from the site’s revision history. As of this addendum no application has been filed.
One sentence rewritten in the same pass, for a different reason. Under the heading “Why an independent institution,” Building This Library said the Library “grew out of Oregon Advocates for School Trust Lands.” Nothing was transferred and no activity was taken over: Oregon Advocates for School Trust Lands continues its own work, and what is true is that the same person leads both. The page now says the Library “was founded by people who also serve Oregon Advocates for School Trust Lands, and is answerable to its readers and beneficiaries, not to a single lawsuit or founder.” That is a rewrite for accuracy of description rather than a correction of a false statement, and it is recorded here so the change is not silent.
021 · September 6, 2026 — An Oklahoma case described with the wrong posture and the wrong remedy on five pages, and a judicial quotation with no source
The wrong case, five times over. The Library’s case file for Oklahoma Education Association, Inc. v. Nigh, 642 P.2d 230 (Okla. 1982), its Oklahoma court-atlas entry, and two Reading Room essays all described Nigh as a decision striking down “appropriation legislation” that diverted school trust revenues “to general state-government purposes.” It is not that case. The five statutes at issue capped the rent the Commissioners of the Land Office could charge on preference-right leases, capped the interest they could charge on farm loans and land-sale contracts, and let a sitting lessee renew a lease without matching competing bids. The vice the court identified was a subsidy, not a diversion: “Just as a State may not use school land trust funds assets to subsidize its highway construction program, a State may not use school land trust assets to subsidize farming and ranching.” 642 P.2d at 236. The pages have been rewritten from the opinion.
A remedy the court refused to grant. The same case file told readers that the court “permanently enjoined the diversion and ordered the revenues restored to the common school fund.” The court did neither. It issued no injunction, and it expressly declined to make its ruling retroactive: the Commissioners and the citizens who had dealt with them “are hereby protected from any liability for any retrospective acts committed under said unconstitutional statutes,” and the decision would “operate prospectively from the date this opinion becomes final.” Id. at 239. Nothing was restored to the fund for the years the below-market terms had run. The corrected pages now say so, and the Oklahoma trust-integrity grade is qualified accordingly.
A quotation from a judge who never sat. The Library’s catalog of authorities carried, as part of its Nigh entry, an anecdote in which the trial judge — named as Cannon — told the parties, “Boys, the party is over.” The words appear nowhere in the opinion, and they could not: Nigh was an original proceeding filed in the Supreme Court of Oklahoma. There was no trial, no trial judge, and no factual record at all — a point the dissent makes in terms. The anecdote is withdrawn. This is the second consecutive state build in which a sentence the Library attributed to a court turned out to have no source, and the Library is treating that as a pattern rather than a coincidence.
Two cases said not to exist. The Library’s Oklahoma entry stated, from June 2026 onward, that “no second verified Oklahoma case is carried in the corpus.” Two were — State ex rel. Williamson v. Commissioners of the Land Office, 301 P.2d 655 (Okla. 1956), and School District No. 23 of Okfuskee County v. Commissioners of the Land Office, 166 Okla. 226 (1933) — and had been since June 10. Both are now published in the Oklahoma appendix.
Two citation traps closed. New Mexico’s Forest Guardians v. Powell relies at one point on an Arizona Court of Appeals decision that the Arizona Supreme Court later vacated. A sweep found that no Library proposition rests on the vacated opinion, and both state appendices now say which decision is which. Separately, the Nebraska appendix now warns that the Platte Valley Public Power and Irrigation District was sued twice under the same case name, and that the 1943 appeal — a sale on contract — is the one New Mexico’s Walker collects, not the 1946 lease-condemnation case the Library holds.
020 · September 3, 2026 — A sentence the Library attributed to the Supreme Court is not in the opinion, and a New Mexico holding had been published backwards
A quotation that does not exist. Two live pages — the New Mexico state page, where it was the pull-quote, and the Reading Room essay “The twentieth-century high-water mark,” where it was attributed to Justice McKenna by name and footnoted to a page range — carried this as the holding of Ervien v. United States, 251 U.S. 41 (1919): “The purposes must be regarded; they must be performed; they admit of no substitution; they admit of no addition.” The sentence does not appear in the opinion. Two independent full reads of the primary, in June and again in September, confirm its absence. The Library’s own book-side citation map had recorded the absence on June 7 and banned the sentence from a manuscript in progress; the ban never reached the public pages. Both are replaced with what the Court did write at 251 U.S. 47: “There is in the Enabling Act a specific enumeration of the purposes for which the lands were granted and the enumeration is necessarily exclusive of any other purpose.”
A holding published backwards. The Library’s case file for Asplund v. Hannett, 31 N.M. 641 (1926), told readers the New Mexico Supreme Court “held … that taxpayer-citizen plaintiffs had standing to enforce the trust against state officials,” and called the case “the early-twentieth-century foundational authority for beneficiary-aligned standing.” The court held the opposite. It dismissed the appeal, holding that “neither in the Enabling Act nor in the Constitution do we locate the power of a citizen and taxpayer to sue for the enforcement of the trust provisions,” 31 N.M. at 646 — and it did so on rehearing, expressly withdrawing its own earlier opinion, which had said what the Library’s page said. The page had been describing a withdrawn opinion as the law. It is rebuilt from the full opinion.
The most-quoted sentence belonged to the court that lost. In Ervien, the line that a private proprietor’s wise administration “could not reach the odious dereliction of a breach of trust in the State,” 251 U.S. at 48, is the District Court’s reasoning for dismissing the government’s bill. That court was reversed, and the Supreme Court affirmed the reversal. The Library’s treatise presented the sentence as the Supreme Court’s answer in six places, five of them adding that the Court was “affirming its result” — which inverts what happened — while the Court’s actual answer, that “the United States, being the grantor of the lands, could impose conditions upon their use, and have the right to exact the performance of the conditions,” appeared nowhere. Corrected throughout the treatise sources. One chapter that carries the same correction is held back from publication under the Library’s standing rule that pages touching active litigation are reviewed by counsel before they change.
October 17, 2026 amendment: the statement above that the chapter is held back from publication under the Library’s standing rule is withdrawn. Corrections 041 and 042 record that the chapter was not held back, and it was corrected on October 16, 2026.
Also corrected, and the New Mexico appendix published. State ex rel. State Highway Commission v. Walker (1956) was cited for a full-value measure it never fixes and for restoration it never ordered, and was said to hold that an attorney general’s advice “carries no weight” — where the court called the executive construction “very persuasive” and merely insufficient to overcome the Enabling Act. It disapproved three attorney general opinions, not two. Forest Guardians v. Powell (2001) was described as denying standing “across the board” on one theory, when the two plaintiff groups lost on different grounds and the court accepted that the schoolchildren were injured in fact. State ex rel. King v. Lyons (2011) was shelved as a full-value case, though the exchanges it voided would have returned the trust more than it gave up. Appendix A — New Mexico is published today, built against all five primary opinions, and records these findings on its face.
019 · August 23, 2026 — Idaho’s grazing holding had been pinned for months to an election-law case, and the Library cited Idaho for a standing rule Idaho refuses
Two Idaho Supreme Court decisions from 1999 carry the same case name, Idaho Watersheds Project v. State Board of Land Commissioners, and sit on adjacent pages of the same reporter volume. They decide entirely different things. The one at 133 Idaho 64 struck Idaho Code § 58-310B. The one at 133 Idaho 55 is a per curiam original proceeding about whether a ballot measure was properly submitted to the voters; the word “grazing” does not appear in it. The Library’s Court Room atlas, a Reading Room essay and a history chapter had all attributed the grazing holding to the second one.
A fiduciary-breach holding that does not exist. The Idaho case file and the essay “Why the courts have mostly held the line” both told readers the court “held that the State Board of Land Commissioners had breached its fiduciary duty by leasing school trust lands at rates below the maximum long-term financial return obtainable through competitive procedures,” and that an administrative valuation scheme producing below-market rents is, on that ground alone, a breach. The words fiduciary, breach, trustee and market appear nowhere in the opinion. The court made no breach finding and valued no rents. It struck a statute, because the Legislature had told the trustee to weigh interests the constitution does not name: “Article IX, § 8 requires that the State consider only the ‘maximum long term financial return’ to the schools,” 133 Idaho at 67. Withdrawn and replaced with the holding the court gave.
Idaho cited for the opposite of what Idaho holds. Three pages — including the essay “The beneficiaries who cannot speak” — placed Idaho among the states whose courts let beneficiary-side plaintiffs enforce the trust, on the strength of a sentence saying the court rejected “the state’s argument that only the Attorney General could pursue such claims.” The phrase “Attorney General” does not appear in the opinion, and no such argument was made or rejected. The plaintiff won as a rejected lease bidder with an individualized injury. Idaho’s actual law on beneficiary standing is Selkirk-Priest Basin Ass’n, Inc. v. State ex rel. Andrus, 127 Idaho 239 (1995), which held that the direct beneficiaries are “the schools (or the school districts of which the individual schools are a part)” and denied standing to two organizations representing neither — closing, in a footnote, the charitable-trust route that would otherwise have been open. The corrected essay says so, and the point it was making survives: a doctrinal split is sharper with a state on the other side of it.
A parallel citation belonging to a different case. Five pages cited the 1999 grazing decision as “133 Idaho 64, 982 P.2d 358.” That Pacific Reporter page belongs to the companion. The correct parallel citation is 982 P.2d 367.
A telling fact that credited the court with a holding it declined to make. The Idaho state page said that when voters approved a 1998 amendment package, “the state’s own Supreme Court struck it down the next spring — courts in Idaho have treated Article IX as binding even on the voters.” The dates check out: the measure passed November 3, 1998, and the writ issued the following spring. The reason does not. The court granted relief on the separate-vote requirement of Idaho Const. art. 20, § 2, expressly limited its review to “the methods and procedures utilized in the passage of H.J.R. 6,” 133 Idaho at 57, and held the substantive challenges time barred. It said nothing about Article IX binding the electorate. The page now says what the court did, which is a narrower and more interesting fact: the trust survived a retrenchment on a procedural technicality.
What the Library had right. Its internal authorities register recorded the correct division between the two 1999 opinions on June 10, 2026, and Chapter 4 of the legal reference manual carries the correct account. The public pages were never brought into line with either. That is the second consecutive verification pass to find the research sound and the step from register to page the place the error lived.
Published the same day: the Idaho state appendix, built from the four Idaho opinions the Library holds and recording what each of them will and will not support. The Idaho state page, the Court Room atlas entry, the case file, the Reading Room essays and the history chapter’s citation note were corrected in the same pass.
018 · August 22, 2026 — the Library’s first state appendix was still the sample edition, and a causal claim the Nebraska Supreme Court rejected was published as fact
The Nebraska appendix was the proving sample for the form every state entry follows. It was written on June 6, 2026, labelled “(v0)” on its own face, and never rebuilt. Every other state appendix had been read back against the full primary opinions; this one had not. Its cross-references still used chapter numbers the treatise had retired, so a reader who followed a pointer landed in the wrong chapter. It is now published as v2, with all four Nebraska opinions read whole.
Every sentence the entry placed inside quotation marks turned out to be verbatim. What was wrong was everything around the quotations. Two Propst page pins had been transposed — the nullity rule is at 156 Neb. at 232 and the express-trust sentence at 233–34, not the reverse. The Ebke posture was wrong: it was an appeal from the dismissal of a declaratory-judgment petition in the district court for Lancaster County, not an original action, and the court struck portions of two enactments rather than one statute whole. And Propst’s affirmance rested on three grounds, of which the Library published one: the court also held that the plaintiff’s own conduct was “inconsistent to a degree sufficient to defeat the granting by the court of the relief he asked,” 156 Neb. at 234–35, and that equity will not enjoin an act already completed, id. at 235.
Two Nebraska case files misquoted the state’s most-cited trust sentence. The Ebke case file and a Reading Room essay both printed the duty of loyalty as “A trustee owes [the] beneficiaries of [the] trust his undivided loyalty and good faith, and all of his acts as trustee…” The court wrote: “It is a fundamental principle that a trustee owes beneficiaries of a trust his undivided loyalty and good faith, and all his acts as such trustee…” The same pages rendered the bidding rule as a trustee “must accept the highest bid, in absence of cogent reasons for not so doing”; the court wrote “A trustee is required to accept the highest bid in the absence of cogent reasons for not so doing.” Four quotations were pinned to “47 N.W.2d at 520” — the opinion’s first page — for passages that sit at 154 Neb. at 249. All are corrected and pinned to the star pages the Library’s copy actually carries.
The Library published a causal claim the Nebraska Supreme Court refused. The Nebraska state page reported that after the Ebke litigation “the trust corpus reportedly gained more than $4 million.” That figure appears in the 1954 fee opinion only as the fee applicants’ own assertion. The court rejected the premise in terms: the additions to the fund “result from the administrative and independent action of the Board of Educational Lands and Funds,” and “Ebke, by this litigation, did not augment the fund.” 159 Neb. at 96. The sentence is replaced with what the court held. The same page credited a case called Gillett with helping finish the job; Board of Educational Lands & Funds v. Gillett, 158 Neb. 558 (1954), is a real case cited inside the fee opinion, but the Library does not hold it and had no basis for the claim.
Two verification flags open since June turned out to rest on false premises, and one of them had put an error on two pages. The appendix and the Nebraska court atlas both told readers that administration of the trust had “shifted to other state offices.” It has not. The Board of Educational Lands and Funds is a live constitutional trustee under article VII, section 6 of the Nebraska Constitution and Neb. Rev. Stat. § 72-201; since LB 1023 (1972) its five members are appointed by the Governor and confirmed by the Legislature. The second flag asked whether article VII, section 9 had been renumbered. It has not been renumbered since 1920 — but its text was amended four times after Ebke, and the trust-fund language the incorporation rule depends on now sits at article VII, section 8. A brief that quotes Ebke’s constitutional text and pins it to today’s section 9 will not find it there. The atlas also carried lease revenue from fiscal 2016–17 as its current figure; it now carries the 2024–2025 numbers the Nebraska state page already used.
Two cautions are now printed rather than left implicit. Platte Valley never uses the words trustee, fiduciary, or compact; its trust language is the single phrase “contractual and constitutional obligation,” and the treatise’s compact framing rests on that phrase. And Propst’s parties were private lessees, so reading its notice rule to bind a state agency or to foreclose a bona-fide-purchaser defense is an extension by argument — defensible, but not a holding. The Library would rather say which of its propositions are arguments than let a reader discover it in front of a judge.
017 · August 21, 2026 — for one day a hornbook chapter’s correction record contradicted the chapter’s own footnotes
Correction 016, published yesterday, reinstated a page pin for State of Utah v. Kleppe, 586 F.2d 756 (10th Cir. 1978), in notes 3 and 26 of the Granting Instruments chapter. It did not reach the correction note at the foot of that same chapter, which still told readers the pin “is now stated as unsettled rather than asserted.” The footnotes said 758. The correction record said the Library had stopped saying 758. Both were on the page at once, and a reader checking the Library’s work would have had no way to tell which one to believe. The note is rewritten: it now records the whole sequence — the assertion, the mistaken withdrawal of August 12, the reinstatement of August 20, and the fact that the note itself was left behind. A correction log that goes stale is a second error, not a record of the first.
The pin is 758, and this pass added a second, independent way of showing it. Star-pagination markers denote page transitions, so text before the first marker sits on the page before it. Beyond that: the run from the opinion’s first word to the *759 marker measures 3,411 characters of visible text, while full pages in the same copy run 4,039 to 4,362. The passage is too short to contain a page break, so all of it sits on one page — 758.
The catalog’s underlying data still carried two entries the Library had publicly retired. The catalog is generated from an internal register of authorities, and where a verification pass has corrected an entry the page publishes the corrected text through an override list. That worked, but it meant the register — the actual source — still said that Deer Valley Unified School District No. 97 v. Superior Court holds trust land “is not state land,” a quotation that appears nowhere in the opinion, and still cited Kleppe with no indication that the judgment was reversed in 1980. Only an exact name-match in the override kept either off the page. Both are now fixed in the register itself, and in the generated data, so the override is a duplicate rather than the only thing standing between the reader and retired text.
Why this pass also names four errors no reader ever saw. The same sweep read four unpublished chapter drafts against the primary opinions. In one, a quotation had been manufactured: the draft had the school-land grants “created a binding permanent trust,” in quotation marks, where the Tenth Circuit wrote that “[t]he specific purpose was to create” one — a statement of congressional purpose turned into an accomplished legal effect — and had dropped the limiting words “of the ‘public land’ states” without an ellipsis. Another glossed Clark v. Stephen D. Lee Foundation, 887 So. 2d 798 (Miss. 2004), as a “fair-market-value floor under the 1817 instrument”; the opinion says reasonable market value, never uses the words “fair market value,” and never mentions 1817. A third described the Kanaly litigation as two opinions when it is three. And the Library’s own provenance header for Kanaly I credited a separate writing by Justice Wuest that does not exist — the opinion is unanimous, and what follows it is a notation that Judge Wuest participated. None of the four reached a published page. They are named here because the Library asks readers to judge its citations, and that is only a fair request if it also reports what the checking catches before publication, not just after.
Amended October 13, 2026. The sentence above — “None of the four reached a published page” — was wrong. Three of the four had: the manufactured Kleppe quotation and the Clark gloss in the hornbook working edition offered for download from the book pages, and the Kanaly two-opinion description in note 13 of the published chapter on the trust character of the grants. Only the fourth, the Wuest provenance header, reached no reader. See correction 040.
016 · August 20, 2026 — a sweep of seven cases the Library had already “corrected” found the corrections had reached one page each and stopped
On June 10, 2026 a verification pass read seven opinions against their full texts and recorded what it found. This pass went back to ask a different question: not whether the research was right, but whether it had travelled. It had not. In every one of the seven cases the finding reached the page that prompted it and no other. What follows is the whole list, because the pattern is the point.
The South Dakota atlas page said two courts cited an opinion decided after they ruled. It reported that Kanaly v. State (1985) is “widely cited nationally — including by the Skamania court in Washington and the Nigh court in Oklahoma.” Skamania was decided in 1984 and Nigh in 1982. The dependency runs the other way: Kanaly cites Nigh at 823 among the sister-state formulations it collects, and the word “Skamania” appears nowhere in it. The Library’s own South Dakota appendix had recorded this correction on June 10, 2026. A verified downstream citer does exist and now appears in its place: Conservation Northwest v. Commissioner of Public Lands, 200 Wn.2d 8 (2022).
The Kanaly case file described the wrong statute, the wrong plaintiffs, and a remedy broader than the court ordered. Senate Bill 221 closed the University of South Dakota at Springfield and handed the campus to the Board of Charities and Corrections; the school’s 40,000 trust acres moved separately, under a different act the court sustained in Merkwan v. State (1985). The plaintiffs were six resident taxpayers, not beneficiaries — the court held that the beneficiaries are the state’s educational institutions and “do not include the general public.” And the court did not order the trust made whole “for any past deviations”; it ordered reimbursement of the full market value of what was transferred, by the end of the 1986 session. The South Dakota state page carried the same 40,000-acre error. Both are corrected, and both now carry the sequel the Library had never published: Kanaly III, 403 N.W.2d 33 (S.D. 1987), where the court records that the reimbursement was in fact made. “This has been done.”
Two Reading Room essays cut a quotation in the place that reversed its point. Both published Kanaly’s central sentence as ending at “donated to the state for educational institutions by the United States.” The sentence continues “and individuals alike.” Those three words are what make the trust corpus broader than the federal grant, and the Library argues exactly that elsewhere on the same site. The truncation was unmarked. Both are restored.
Arizona: the Library had two live pages giving different grounds for the same decision. The Arizona appendix said Deer Valley Unified School District No. 97 v. Superior Court (1988) was decided on the Arizona Constitution alone, on independent state grounds. Chapter 1 said condemnation was barred “without Enabling Act § 28 compliance.” The appendix was right. Under Lassen the federal act would have permitted this condemnation — “the federal act allows a state agency to acquire an interest in school trust land by either negotiation or condemnation” — and the Arizona court declined to follow it, calling the Enabling Act “merely … the minimum protection.” Chapter 1 is corrected. The Deer Valley case file, written in May and never revisited, carried eight further defects, including a closing sentence telling readers that a departure from the trust is cured by “full compensation at appraised value.” That is the precise proposition the opinion rejects: appraised value is what condemnation guarantees, and the court held it insufficient, because the auction is what discovers value above appraisal. It also credited the opinion with citing Kanaly and Pettibone, neither of which appears in it, and with using the words “sovereign” and “capacity,” which do not appear in it either.
Alaska: the Library repeatedly placed two federal trusts inside the wrong statute. Six surfaces said, in one form or another, that the 1958 Alaska Statehood Act created the Mental Health Trust and the University of Alaska grant. The mental-health grant is section 202(e) of the Alaska Mental Health Enabling Act of 1956; the university grant is the Act of January 21, 1929. Section 6(k) of the Statehood Act confirmed and transferred both. The Alaska state page carried the error as a display element: “When Congress wanted to write fiduciary trust language in 1958, it knew exactly how — it did so for Alaska’s Mental Health Trust in the very same Statehood Act.” The point survives the correction and arguably lands harder, but the fact as stated was wrong.
The Alaska case file reported a clean win in a case the court largely reversed. State v. University of Alaska (1981) affirmed the breach holding but reversed the trial court’s invalidation of the park statute, held the legislature did have power to make the disposal, directed an award in inverse condemnation instead, and reversed the attorney-fee award. None of that appeared. The entry also named the wrong granting act, the wrong plaintiff, and the wrong actor (the legislature made the disposal, not a parks agency), added “students” to a beneficiary class the opinion describes as the institution, and attributed to the Alaska court two quotations it was itself quoting — one from Lassen, one from Scott on Trusts. The court atlas carried the same two misattributions.
A quotation attributed to the Tenth Circuit belongs to a district court. The Library’s review of Kevin Marsh’s 2007 article said Utah v. Kleppe was “unambiguous: the grants were not unilateral gifts but bilateral compacts entered into between two sovereigns.” The words “unilateral,” “gift” and “sovereign” appear nowhere in Kleppe. The formulation is from State of Utah v. Andrus, 486 F. Supp. 995, 1001 (D. Utah 1979). The same page told readers the Library “flags the doctrinal contest rather than presenting Kleppe as wholly settled ground” while nowhere mentioning that the judgment was reversed in 1980. Of twelve surfaces citing Kleppe, six carried the reversal and six did not; the ones that did not are corrected.
A correction the Library made was itself wrong, and is reversed. On August 2, 2026 the Utah appendix withdrew the page pin for the two Kleppe quotations, reasoning that the held copy’s star pagination begins at *759 and so cannot settle whether the sentences sit at 757 or 758. That inference was mistaken. Star pagination marks page transitions, so text preceding the first marker sits on the page immediately before it; the run 759 through 774 is unbroken, and the quoted paragraph precedes *759. The pin is 758, as first recorded on June 8, 2026, and it is reinstated. A reference work that withdraws a correct citation has published a false statement about its own holdings, and the appendix now says so.
The Mississippi atlas page stated the trusteeship backwards. It said each school district “functions as trustee for the Sixteenth Section lands within its boundaries.” Clark v. Stephen D. Lee Foundation (2004) holds the opposite: “School districts do not hold title to sixteenth section lands; rather, title to trust lands was granted by the federal government to, and resides in, the State.” The Library’s Mississippi appendix had withdrawn that sentence on August 12, 2026. The same page attributed the word “spoliation” to the case law; it appears in none of the seven Mississippi opinions the Library holds. And it twice called Clark a “fair-market-value floor” case, a phrase the appendix expressly warns against — the opinion says reasonable market value, and it enforced nothing, having reversed and remanded without reaching the adequacy question at all. Chapter 1 stated a holding of constitutional invalidity the court reserved, and sourced the valuation benchmark to the 1817 instrument, which the opinion never mentions.
The Nebraska appendix asked a question that had been answered twice. Its account of Platte Valley ended with a bracketed note asking that the preference-right formulation be verified against the full opinion. It had been — in June 2026, and again in a pass that overruled the June reading. The finished answer went into the internal file and never reached the published page, which is still served from the sample-edition text while every other state appendix has been rebuilt. The answer is now on the page, in prose: the phrase “preference right but no absolute right” is a paraphrase and not a quotation from this opinion; the supporting language is at 147 Neb. at 302–03 (“Clearly the section does not give the lessee an absolute right to a new lease”); and the crisper formulation belongs to the Nebraska court’s own later characterization in Ebke, 154 Neb. at 248. The same entry called the tract a “school section”; it was part of Section 8 in Keith County, about 272 acres.
One note on those brackets, since readers ask. The legal reference manual’s pages are rendered from their source files unchanged, so its [VERIFY] flags are visible on the page by design — that is the Living Edition promise, that a reader can see what the Library has not finished checking. Everywhere else on the site the flags are stripped before publication. A hedge written into an essay or a state page therefore does not reach the reader, and this pass replaced one such hedge with plain prose rather than leave a silent assertion standing.
Two further items are recorded here without being repaired, because the repair is a question of policy rather than of fact. Archived earlier versions of state pages, reachable from the version bar, carry three errors this sweep found: a Kleppe quotation on the Utah page that does not exist in the opinion; the Alaska Statehood Act misattribution; and, on the South Dakota page, a misquotation and a reversed chronology for Merkwan. Those panels are preserved as they shipped. Whether to repair them silently or to overlay a correction notice is a decision the Library has not yet made, and it is recorded here so that a reader who opens one of those panels knows what is in it.
Sources: Kanaly v. State ex rel. Janklow, 368 N.W.2d 819 (S.D. 1985), 401 N.W.2d 551 (S.D. 1987), and 403 N.W.2d 33 (S.D. 1987); State v. Platte Valley Public Power & Irrigation District, 147 Neb. 289 (1946); State of Utah v. Kleppe, 586 F.2d 756 (10th Cir. 1978), and Andrus v. Utah, 446 U.S. 500 (1980); State v. University of Alaska, 624 P.2d 807 (Alaska 1981); State v. Weiss, 706 P.2d 681 (Alaska 1985); Deer Valley Unified School District No. 97 v. Superior Court, 157 Ariz. 537 (1988); and Clark v. Stephen D. Lee Foundation, 887 So. 2d 798 (Miss. 2004). All are held in the Library’s research collection and all were read whole for this pass.
015 · August 20, 2026 — the Library reported Jensen v. Dinehart backwards on its Utah state page, and published Justice Oaks’s separate opinion as the holding on a second page
Jensen v. Dinehart, 645 P.2d 32 (Utah 1982), is the decision the Library treats as the hinge of the modern Utah story. A scheduled verification pass read it against the full opinion — majority and separate opinion — held in the Library’s research collection. Two live pages described it wrongly, and they described it wrongly in opposite directions from each other.
The Utah state page had the result reversed. It said the Utah Supreme Court “ruled for the trust,” affirmed that mineral proceeds must stay in the permanent fund, held the 1939 constitutional amendment invalid under the federal Enabling Act, and that “the auditor lost.” The opposite is true. The auditor won. Chief Justice Hall, for the Court, held that “the mineral proceeds from the school sections are properly placed in the Uniform School Fund” — the currently expendable fund — “whenever such sections were acquired by this state,” and remanded for entry of judgment on that basis, setting aside the trial court’s contrary declaratory judgment. The page went on to say the 1983 legislature acted against what Jensen had held. It acted on it.
Where the trust-protective sentence actually comes from. The holding that the 1939 amendment violated the Enabling Act was the trial judge’s — Christine Durham, then of the Third Judicial District — and it reaches the reporter only because Justice Oaks quoted her memorandum in a footnote to his separate opinion. Oaks concurred as to sections acquired under the 1927 Jones Act and dissented as to sections acquired under the Enabling Act. His sentence that there are “no words in the Jones Act or its legislative history that exhibit any intent to remove or modify the trust restriction Congress had imposed on sections granted under the Enabling Act” is the most-quoted line in the case. It is not the holding.
The court-atlas page published that sentence as the holding. Utah’s entry in the court atlas said the case “[h]eld that nothing in the Jones Act removed or modified the trust restriction Congress imposed on sections granted under the Enabling Act.” That is Justice Oaks, at *37, and it did not command a majority. The entry now states the majority holding and attributes the separate opinion by name.
How long this sat. The Library corrected this same misattribution in the treatise’s granting-instruments chapter and in its internal authorities register on June 10, 2026. As with correction 014, the fix reached one chapter and stopped there. The Utah appendix to the treatise and the Library’s catalog were also already correct. Four other pages were not. This is the second time in five days that a verification pass has found a recorded correction that never propagated, and the Library is now checking previously-corrected entries as a standing part of each pass rather than only new ones.
Two smaller corrections in the same pass. The Reading Room entry for the case attributed to the Court a finding it never made — that it “treated the constitutional language as ambiguous … and resolved the ambiguity in favor of the legislature’s authority.” The Court made no ambiguity finding; it reasoned from United States v. Sweet and from the Jones Act’s extending language. That entry also carried parallel citations (4 Educ. L. Rep. 640; 1982 Utah LEXIS 913) that cannot be confirmed from the copy held here; they are withdrawn pending verification rather than left standing. A footnote in the Western Stack essay pinned Justice Oaks’s opinion to “36–40”; the opinion ends at *37.
014 · August 16, 2026 — the Library quoted Chief Justice Taney’s dissent as the opinion of the Court, and printed a Vincennes quotation that does not exist
Trustees of Vincennes University v. Indiana, 55 U.S. (14 How.) 268 (1852), is the oldest case the Library carries. Four of its pages described it wrongly, in the same way, and one of them printed a quotation that appears nowhere in the opinion. A scheduled verification pass read the case against the full opinion — majority and dissent — held in the Library’s research collection.
The misattribution. The sentence the Library cited most often from this case — lands “granted to the State, as the trustee to administer the trust” — is not the holding. It is from Chief Justice Taney’s dissent, joined by Justices Catron and Daniel, at *279–80. The Library’s entry in the Reading Room introduced it, and a second dissent passage, with the words “From Justice McLean’s opinion.” The second passage is Taney describing what he took to be the majority’s error. The granting-instruments chapter of the treatise had this right since June 10, 2026; the correction never reached the other pages. It has now.
The quotation that does not exist. The lineage entry for Vincennes carried a block quotation attributed to page 274: “The grant in this case was made for the purpose of founding an institution of learning … a clear case of a contract by which the state has been brought under solemn obligations.” Neither phrase occurs anywhere in the opinion or the dissent. It has been replaced with verified text from the Court’s opinion at *274.
Two smaller errors, same case. The Library said the Court “ordered the state to account for the value of the lands and proceeds it had taken.” It did not: it reversed the Indiana Supreme Court’s dismissal, with costs, and remanded for further proceedings. And the three principles the Library attributed to Vincennes alone were drawn by the Montana Supreme Court in Department of State Lands v. Pettibone, 702 P.2d 948, 953 (Mont. 1985), from Vincennes and Springfield Township v. Quick, 63 U.S. (22 How.) 56 (1859).
What the case actually holds, and why it matters. The trust the Court enforced vested in a chartered university, not in the State: the trustees “constituted an eleemosynary corporation, in which the State has no property, and can exercise no power to defeat the trust.” The Supreme Court itself later read the case on that ground in Alabama v. Schmidt, 232 U.S. 168, 174 (1914). This matters because Vincennes has been carried, here and in the wider field, as the earliest authority for the receiving state as trustee of school lands. It is not. That proposition rests on Cooper v. Roberts (1855) and the cases after it, which is where the Library now places it.
Pages corrected. The Reading Room entry for Vincennes; the Case File annotation and the Court Room summary; the doctrinal-lineage entry; and the treatise’s working-edition status note. One page is not yet corrected: the trust-character chapter repeats the misattribution in its section 3.2 and its footnote 3, with a page citation that lands in the dissent. That chapter is held for review before republication for reasons unrelated to this correction; the error is recorded here rather than left unmentioned.
October 17, 2026 amendment: the statement above that the trust-character chapter is held for review is withdrawn. Correction 041 records that the chapter is not held for review, and correction 042 records that it was republished three times while this entry said it was held. The chapter was corrected on October 16, 2026.
013 · August 12–13, 2026 — a full audit of the Library: 229 errors found across 441 pages, including a fabricated quotation attributed to a federal judge
The Library audited every page it publishes. This entry reports what the audit found, including what it found about the audit itself. The numbers are given in full because a corrections log that records only small errors is not a corrections log.
What was found. 229 statements were wrong, stale, or
contradicted another page of this site. The largest groups: litigation
status overtaken by the July 23 and July 24, 2026 rulings and never
updated, including a Court Room page that reported motion-to-dismiss
briefing as continuing in a case that had been decided on summary
judgment; 25 pages still directing readers to schooltrusts.net after the
August 10 consolidation, among them a verification chapter that sent
readers to a path that no longer exists; 47 state dossiers stamped
Draft: Pass 1 prototype, 2026-04-30
; five book chapters shipping a
raw editorial placeholder in body text; and a page stating that the
Library is operated by Oregon Advocates for School Trust Lands
,
which is false and contradicts the Library’s governing instruments.
The most serious finding. The Library’s entry for Branson School District RE-82 v. Romer, 161 F.3d 619 (10th Cir. 1998) attributed the opinion to Judge Stephanie K. Seymour and printed a block quotation from it. The opinion is by Judge Ebel. Judge Seymour’s name appears once in the opinion, in a citation to her dissent in an unrelated 1984 case. The quoted sentence does not appear in the opinion at all. The entry also linked to the wrong record and described the standing holdings without saying that the school districts lost on the merits. The entry has been rewritten from the opinion, and the correction is stated on the page itself. Nobody outside the Library reported this; the Library found it by auditing itself, which is the only reason it is being reported now rather than never.
What the audit got wrong. The corrections were made with AI assistance, and a second, adversarial pass found that the correcting work had itself introduced 59 new problems — mostly one repeated mistake: language that had been honestly provisional was replaced with confident absolutes the Library’s own data contradicts, such as stating no Attorney General opinions were on file for states whose dossiers publish six of them. Two were serious: a source line was made to attribute 22 state dossiers to Margaret Bird, who did not source them, and footnotes in one chapter were converted into citations to Library material that does not contain the cited passages. All 59 were repaired before publication. None reached a reader.
What changed as a result. A fabricated quotation is not an error of care; it is a failure of method, and instructing a writer to be careful is not a method. The Library is building a check that resolves every quotation attributed to a court opinion against the opinion’s own text, so that a quotation which does not appear in its source cannot be published at all. Where a claim cannot be checked that way, it will say so on the page rather than pass silently. The results of each audit, including how often the checks find something, will be published.
012 · August 12, 2026 — the welcome tour claimed the Library holds "240 years of receipts," miscounted its own rooms, and used internal vocabulary in the first sentence a visitor reads
The walking tour that greets a first-time visitor said: Eight rooms
open today, more being built; one substrate beneath them all. The Library
has 240 years of receipts on America's school trust lands and funds.
Three things were wrong with it. Nine rooms are open, not eight. The
Library does not hold 240 years of receipts and has never claimed to
anywhere else — the Counting House exists
precisely because many states have not published their accountings, and
an unqualified claim of a complete 240-year record contradicts the
Library's own finding. And substrate
is an internal working word
that means nothing to a reader; the same vocabulary was removed from the
catalog on August 10 (entry 010) and was missed here.
The step now describes what the Library gathers and states plainly that what each state has not published is part of the record. Found in the course of acting on a reader's note that the site did not say, near the top of its front page, why anyone outside the field should read it — a note from Barry Shane, a director, whose suggestion also produced the opening paragraphs now on the home page.
011 · August 12, 2026 — the secretary's portrait was missing on the About page and in the booklet, and the booklet gave the founder the largest plate of any person in it
About page: Kenneth Mike
Magee's board card carried a placeholder
where a photograph and an account of him should have been, reading
A photograph and a short account of Mr. Magee will be published here
when he supplies them.
He supplied both on August 12, 2026, and the
card now carries his portrait and a biography. The account is drawn from
material he provided and names, as the Library's own published essays
already do, that he and Dave Sullivan cofounded the Corvallis PC Club in
the 1980s and have been friends since — a relationship a reader weighing
this board is entitled to see on the page rather than have to find.
Booklet, Figure 14: the first edition reproduced that placeholder as a
plate and captioned it An institution that will not fake a portrait is
telling you how it treats a record.
The frame is now his portrait, and
the caption records both the gap and its closing rather than removing the
evidence that there had been one.
Booklet, Figure 12: the photograph of Dave Sullivan with Barbara K. Sullivan ran as a full-height bleed, roughly seventy per cent of the page and the largest plate given to any person in the booklet, while the two directors who are not the founder appeared on the facing page at a fraction of that size. It now runs at the same contained plate size the booklet uses elsewhere. No text about any of the three changed except the paragraph naming the secretary, which now records his own working life.
The booklet was reissued as a second edition the same day. The first
edition's file hashes were web
926e1a184aad7d4961adb254a1bf69da009021d6a0122c4145dbbe577fd3ad67
and press
51d5ac3f90a0b9a876b77bada71b7e0f623c966fddb1baf461903259ca1938d5;
the second edition's are published on the
booklet page.
010 · August 10, 2026 — the catalog page carried a Verified badge no holding has earned, and a collections note omitted the Elliott's 2022 decoupling
Catalog page: removed a Verified status badge that no holding has yet earned under the Library's published standard (the label requires a second, independent reviewer the Library does not yet have); removed two catalog rows pending accession review; replaced internal file-path shorthand with public names; and removed stale counts.
Collections: corrected a note that described the Elliott State Forest as school trust land without noting that the State Land Board decoupled it from the Common School Fund in 2022.
009 · August 10, 2026 — the Court Room reported a case status three months out of date, and omitted the ruling that went against the plaintiffs
The Oregon case page carried the heading Procedural posture as of
2026-05-18
and reported the last docket event as January 28, 2026.
Two things had happened since and neither appeared anywhere in the
Library: on July 23, 2026 the Oregon Supreme Court denied review in
S072734, making the Court of Appeals standing decision final; and on
July 24, 2026 the Coos County Circuit Court granted the defendants
summary judgment in 24CV38372, holding that the State owes no legally
enforceable fiduciary duty, and canceled the trial that had been set for
August 18–28, 2026.
The second omission is the one that matters. The Library keeps the record
without regard to whose argument it helps
, and the ruling it had
not published is the one that went against the advocacy organization the
Library grew out of. A gap shaped like that is not a scheduling problem.
The page now states the ruling first, and the opinion letter is published
in full at
/court/filings/2026-07-24-combs-summary-judgment-letter-24cv38372.pdf
so that a reader can check the Library against the court rather than
taking its summary on trust. Published in the stale condition from
May 18 to August 10, 2026.
008 · August 9, 2026 — two ledgers, merged and renumbered
The Library kept two public corrections ledgers on two sites: one at schooltrusts.net — the ledger that became this one — and a second at schooltrusts.org. They were merged on August 9, 2026, and since the August 10 consolidation the Library publishes at schooltrusts.org, to which schooltrusts.net now redirects. Each numbered its entries from 001, and the numbers collided — three events were recorded on both ledgers in different words, one event only here, three only there, and two different corrections both carried the number 004. A reader who cited "correction 004" could not be sure which correction was meant. The two ledgers were merged into this one on August 9, 2026, and every entry was renumbered from 001 in date order. Entries 001 through 004 keep the numbers they carried on schooltrusts.net; the three schooltrusts.org entries with no counterpart here became 005, 006, and 007.
Where both ledgers recorded the same event, the merged entry carries every detail either one had. No two accounts of the same event contradicted each other on a fact. They differed in completeness: schooltrusts.net gave the Oregon Registry number for the incorporation and the reason the help page now gives for not inviting donations; schooltrusts.org quoted the bylaws draft banner more fully. The merged entries take the fuller version in each case. The schooltrusts.org ledger also described itself as opening with three entries; this ledger opens with four, because the entry recording this log's own absence was never carried on that site.
Concordance of old numbers to new:
| Entry | schooltrusts.net | schooltrusts.org | Now |
|---|---|---|---|
| Sitewide footer, "is organizing as" | 001 | 001 | 001 |
| Bylaws draft banner, "not adopted by any board" | 002 | 002 | 002 |
| The donations rationale | 003 | 003 | 003 |
| This log existed only as a promise | 004 | not recorded | 004 |
| Certificate of adoption published with blanks | not recorded | 004 | 005 |
| The founding-board roster | not recorded | 005 | 006 |
| Organizational record page, "nothing here has been filed" | not recorded | 006 | 007 |
007 · August 9, 2026 — superseded: "Nothing here has been filed or adopted yet"
The organizational record page carried an opening notice: "Nothing here has been filed or adopted yet." True when written; the filings and adoptions it anticipated were completed between July 10 and August 3, 2026, and the body of the page had already been rewritten to say so. The stale notice stood above the corrected text from August 3 to August 9, 2026, and has been removed.
006 · August 9, 2026 — superseded: the founding-board roster
The About page stated: "The founding board: David Sullivan, President · Barbara K. Sullivan, Treasurer · Kenneth Magee, Secretary." True when written; on August 9, 2026 the board added Barry Shane and accepted Barbara K. Sullivan's withdrawal, and the offices were reassigned — David Sullivan, President and Treasurer; Kenneth Magee, Secretary; Barry Shane, Director. The page now carries the current board.
005 · August 9, 2026 — corrected: a certificate of adoption published with blanks
The certificate of adoption reproduced at the foot of the Bylaws, the Constitution and Readers' Bill of Rights, and the Conflict of Interest Policy on the governance page was published with a blank effective date and a blank signature line — while the head of each page certified adoption effective August 3, 2026, and the executed originals carry that date. A reader who scrolled saw the Library's founding instruments presented as unexecuted. The blanks now carry the executed facts, with a note that the signed originals are held in the corporate records. Published in that condition August 6–9, 2026.
004 · August 3, 2026 — this log existed only as a promise
The corrections policy linked to this page before the page existed ("It ships in a follow-up update"). A library that promises a public ledger should not leave the ledger as a dead link. The log now exists, and records its own absence.
003 · August 3, 2026 — superseded: the donations rationale
The Library's how-to-help page stated that donations could not be invited because the Library's charitable registrations were "not yet complete." True when written; Oregon Charitable Activities Registration No. 72571 was completed July 10, 2026. The page now states the true, chosen posture: documents and hands before dollars.
002 · August 3, 2026 — superseded: "not adopted by any board"
The bylaws page carried a draft banner describing the bylaws as "a working draft … not adopted by any board." True when written; Bylaws Version 7 were adopted by unanimous written consent effective August 3, 2026, and the page now carries the adopted text with its certification note.
001 · August 3, 2026 — superseded: "is organizing as"
The sitewide footer stated the Library "is organizing as a nonprofit public benefit corporation under Oregon law." True when written; incorporation was completed July 21, 2026, when the Articles of Incorporation were filed with the Oregon Secretary of State (Registry No. 259005891), and the footer now carries the current status statement.
To challenge anything the Library publishes, use the Submit a Correction control on any page, or see the corrections policy. No payment, account, or agreement with the Library is required.
