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 Entries that were true when written and were overtaken by events are marked superseded rather than corrected; the Library distinguishes error from supersession.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

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 Withdrawn and replaced with the holding the court gave.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.

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.

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: this one at schooltrusts.net and a second at schooltrusts.org, which is being merged into this site. 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:

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.