1 re 1 - Signed by JUDGE J. MICHAEL SEABRIGHT on 3/3/2023. Case Opinions Available from the U.S. Government Printing Office. . McManis Faulkner var today = new Date(); var yyyy = today.getFullYear();document.write(yyyy + " "); | Attorney Advertising, Copyright var today = new Date(); var yyyy = today.getFullYear();document.write(yyyy + " "); JD Supra, LLC. Ohiorequires parallel citation. You need only cite a case in full the first time it is cited in a legal memo or brief. Cal.] Here, for example, arecitations to a case that was decided in 2014,but notyet published in the United States Reports as of 2017: Riley v. California, 134 S. Ct. 2473 (2014), Riley v. California,189 L. Ed. In addition, under Rule 32.1 (a), a court may not place any restriction on the citation of such opinions. See, e.g., State v. Zais, 790 N.W.2d 853, 861 (Minn. Ct. App. 2012),rev'd, 571 U.S. 429(2014). July 28, 2010). For Michigan practitioners, those rules differs depending on whether you're in the Michigan Supreme Court or Court of Appeals, or in the Sixth Circuit. 0000001516 00000 n
(3) Modifies, explains, or criticizes with reasons given, an existing rule of law; Protocol for Disclosure of Sentencing Materials. Federal rules provide that federal courts must allow parties to cite unpublished (or unreported) opinions issued on or after January 1, 2007. 0000010042 00000 n
If you are citing to an authority that was not cited in the immediately preceding citation or you are citing to a case that was cited in the immediately preceding citation with another source, you will use a different short form. See "Jurisdiction Tables and Abbreviations," above.) Digital Realty Tr., Inc. v. Somers, 138 S. Ct. 767 (2018). To cite to a case in the Federal Reporter, list the following six elements in order: Universal City Studios, Inc. v. Corley, 273 F.3d 429 (2d Cir. Jones v. Southpeak Interactive Corp. of Delaware, 777 F.3d 658 (4th Cir. nFcrH LKK+ _O@f7 m `~$6J Pincites are placed after the page on which the case begins, separated by a comma and one space. 0000014204 00000 n
2012). 2015). 0000008042 00000 n
Appeal from the United States District Court for the Eastern District of North Carolinaat , Raleigh. Californias Electronic Discovery Act, enacted in 2009, was largely modeled on the federal rules. When citing an unpublished opinion or decision a party shall include an electronic citation indicating where the . Some states have more than one district court, so you will indicate in which district court the case was decided. . Nevertheless, you will oftensee parallel citations to S. Ct. and L. Ed. In 2014, the United States Supreme Court reversed the First Circuit Court of Appeals decision in Lawson v. FMR LLC. [2] In California state courts, unpublished opinions, with few exceptions, may not be cited. 2001). For all other state abbreviations, there should be a space between the geographical abbreviation and the district court. 2; Santa Ana Hosp. Y0TpktX`J6czf~%s3b`P*t0wX~!l> M o00:5B+|2)_f r}4#o0 ">
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(A) Unless otherwise ordered under (2): (A) An opinion is no longer considered published if the rendering court grants rehearing. Thus, federal courts in California generally can (and often do) rely on unpublished orders and opinions from district courts and courts of appeals from circuits other than the Ninth Circuit. Moreover, each district court falls under the jurisdiction of a circuit court, and the opinions of that circuit court will be binding on that district court. Factors such as the workload of the court, or the potential embarrassment of a litigant, lawyer, judge, or other person should not affect the determination of whether to publish an opinion. Supp.,F. Supp. These tables give the various abbreviations for the U.S. Federal Courts including the U.S. Supreme Court, U.S. Court of Appeals and U.S. District Courts. (d) When a published opinion may be cited. . 2001), F.3d [third series of the Federal Reporter], Like the federal courts of appeals, decisions from the nation's district courts are not compiled in an official reporter; there is none. 50 West San Fernando Street,10thFloor
The Washington proposal uses the language from the federal rule to describe the various synonyms for "opinion" and "unpublished." California has no rule prohibiting the citation of unpublished out-of-state or unpublished federal opinions. Grp., Inc., 520 F. Supp. as well as between the longer abbreviation Supp. 2d 167 (D. Mass. The Bluebook requires a parallel cite to the regional reporter when citing to the public domain citation. Specialized federal courts, such as the U.S. Bankruptcy Court or the U.S. Tax Court, have slightly different citation rules. Second, the Committee decided to insert into the Committee Note references to the studies conducted by the Federal Judicial Center (FJC) and the Administrative Office (AO). 2d" or "F. Supp. 0000016020 00000 n
(At its June 1516, 2005, meeting, the Standing Rules Committee with the advisory committee chair's concurrence agreed to delete sections of the Committee Note, which provided background information on the justification of the proposal.) To cite to an unpublished case, list the following elements in this order: Name of the case (italicized or underlined); Docket number; Database identifier; The abbreviation for the court that issued the decision (within open parenthesis); The full date of decision (within closed parenthesis). The correct Bluebook citation nowreflects itssubsequent history: Lawson v. FMR LLC,670 F.3d 61 (1st Cir. [2] People v. Williams (2009) 176 Cal.App.4th 1521, 1529: We realize that depublished and unpublished decisions are now as readily available as published cases, thanks to the Internet and technologically savvy legal research programs. A citation to a case in the Supreme Court Reporterand the United States Supreme Court Reports, Lawyers' Editionhas the same five elements as a citation to the United States Reports,except the reporter abbreviation andvolume and page numbers are different. (a) Citation Permitted. (F. 0000014126 00000 n
Only those unpublished decisions issued after January 1, 2007 may be cited. (1) The Supreme Court may order that an opinion certified for publication is not to be published or that an opinion not certified is to be published. Many cases are unpublished, but still available in databases, such asWestlaw, Lexis, Bloomberg Law, or elsewhere. 0000013438 00000 n
(1) The Supreme Court may order that an opinion certified for publication is not to be published or that an opinion not certified is to be published. 0000015478 00000 n
on Judiciary, Analysis of Assem. Pincites can consist of more than one page, in which case you should provide a page range. In the system of common law, each judicial decision becomes part of the body of law used in future decisions. Opinions and memorandum opinions not designated for publication by the court of appeals under these or prior rules have no precedential value but may be cited with the notation, " (not designated for publication)." (b)Civil Cases. 2; Santa Ana Hosp. (7) Makes a significant contribution to legal literature by reviewing either the development of a common law rule or the legislative or judicial history of a provision of a constitution, statute, or other written law;
In others, the old "Delaware style" of citation is required for case citations. The correct Bluebook citation reflects itssubsequent history: Lawson v. FMR LLC,670 F.3d 61 (1st Cir. A lawyer must exercise care when citing authority in either federal or state court. While on the GPO website you could further refine your search. Decisions of the United States Courts of Appealsare usually found in one of two reporters: Note that ordinals like2d and3d in the examples above are treated by Bluebook rules as single capital letters,which is why there is no spacebetween F. and 2d in F.2d or F. and 3d in F.3d. In California state court, trial court opinions and unpublished California appellate opinions should not be cited. When citing an unpublished case, refer to rule B10.1.4 or 10.8.1. Rule 1:36-3 provides that with certain exceptions, "no unpublished opinion shall be cited by any court.". 0000002019 00000 n
([m]any of the bills specific provisions are drawn from recently enacted federal rules . For example, in the citationRoe v. Wade, 410 U.S. 113, 115 (1973), the pincite is 115. Counsel's Request for Disclosure. You will cite: The long form of Roe v. Wade: Roe v. Wade, 410 U.S. 113 (1973). 3d"); The abbreviation for the district court that issued the decision (within parenthesis); The abbreviation for the court that issued the decision (within open parenthesis); The full date of decision (within closed parenthesis). 3 0 obj
[4] See TBG Ins. (As added Apr. Reported Opinions. 1. (b) Exceptions You should indicate the first and last page of the range separated by a single dash. Ct. App. For states that are abbreviated with one capital letter and lower case letter(s), such as Virginia, abbreviated "Va.", there will be a space between the district court and state abbreviations (E.D. While some rules have harmonized over time,[1]other procedures are entirely distinct. 0000003855 00000 n
(F. Supp." Orders Amending Local Rules. 0000011602 00000 n
High Profile Cases 1:10-cv-00051 1:10-cv-00051-MAC-KFG In The Matter of The Complaint of AET Inc. Limited SOLAS OLED LTD. v. SAMSUNG et al. Home Assurance Co. v. Nat'l R.R. De-publishing non-precedential district court opinions. , No. 0000020456 00000 n
The F.R.A.P govern only the federal appellate courts, so Rule 32.1 doesnt apply to the Arizona District Court.5 But Im not aware of a F.R.C.P., an Arizona district court local rule, or a Ninth Circuit or district court case that prohibits citing unpublished decisions to the district court, so, again, I think . Build a Morning News Brief: Easy, No Clutter, Free! In some cases, it can be used as a persuasive authority. 0000008515 00000 n
As of July 1, 2012, appellate cases are no longer published in the print reporter Ohio Appellate Reports. May 2, 2012) (citing Hutchinson v. Staton, 994 F.2d 1076 (4th Cir. 0000015910 00000 n
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A citation to a case in the United States Reports includes the following five elements: Name of the case (underlined or italicized and abbreviated according to Rule 10.2) A citation to a court of appeals case in the Federal Reporter includes the following six elements: Universal City Studios, Inc. v. Corley, 273 F.3d 429 (2d Cir. On request of the court or a party, a copy of an opinion citable under (b) must be promptly furnished to the court or the requesting party. .). The case retains that name even if one or more parties were added on either side or intervened, or if a different party was substituted for the original plaintiff or defendant. For instructions on how to cite a case generally, see BluebookRule B10. For the fiscal year 2017, in Division One of the Arizona Court of Appeals, a total of 621 civil cases were terminated, with only 69 (11%) by published opinion. The changes made by the Advisory Committee after publication are described in my May 14, 2004 report to the Standing Committee. Rule B10.1.2explains more on how to cite to the correct reporter. Any citation to the Court of Appeal opinion must also note the grant of review and any subsequent action by the Supreme Court. 2000) 133 F.Supp.2d 1164, 1167-1168 [citing and relying on an unpub-lished Third Circuit case].) Year the case was decided (within parentheses). Citation of opinions (a) Unpublished opinion Except as provided in (b), an opinion of a California Court of Appeal or superior court appellate division that is not certified for publication or ordered published must not be cited or relied on by a court or a party in any other action. 2022 California Rules of Court. Accordingly, citation of unpublished opinions in briefs, memoranda, and oral arguments in the trial and appellate divisions is disfavored, except for the purpose of establishing claim preclusion, issue preclusion, or the law of the case. fD"LMhU"06&C^l}4. Arizona District Court Yes. (The abbreviated name of the state court's official reporter is always the same as the abbreviated name of the state's highest court. 0000017261 00000 n
[9] N.D. Cal. (The studies are described below. , No. In the text of a law review article, italicize the name of a case. Civil Cases Superior Court Civil Rule 107(c)(4) provides that: The following shall be the form of citations: a. Pursuant toRule 6.1(a), there is no space between adjacent single capital letters (e.g., U.S.), while there is a space between a single capital letter and a longer abbreviation (e.g.,S. Ct. and L. Lawson v. FMR LLC, No. xb```)B?(A/0f' Z%8y1qS;}n>*F+G.0aBr
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Instead, many cases from the district courts arepublished in West'sFederal Supplement. (2) When the opinion is relevant to a criminal or disciplinary action because it states reasons for a decision affecting the same defendant or respondent in another such action. #: 73 Filed: 10/14/09 Page: 1 of 14 . 2007). 0000018410 00000 n
Accordingly, citation of unpublished opinions in briefs, memoranda, and oral arguments in the trial and appellate divisions is disfavored, except for the purpose of establishing claim preclusion, issue preclusion, or the law of the case. These look something like this: Tyree v. Keane, 400 Mass. [10] See Am. While you will most often cite to cases in reporters, only a small percentage of cases are actually designated for publication by a court and published in a reporter. Federal case citations usually indicate the deciding court and year in a parenthetical following the reporter citation: For example, theLawson v. FMR LLCcase was eventually reversed by the United States Supreme Court. Unpublished opinions issued before 2007 may be cited to the courts if permitted by the courts' local rules. Rule 32.1(b) applies to all unpublished opinions, regardless of when they were issued. For purposes of citation to California authorities, this article follows the California Style Manual (4th ed. That does not give counsel an excuse to ignore the rules of court. [6] California Rules of Court, rule 8.1105(e). %PDF-1.4
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Rule 32.1. If you need to include a pinpoint citation to, for example, a quotation or the holding of a case, add the page number after the first page. Further the following case laws also point to the fact that unpublished opinions cannot be cited. 10-2240, 2012 WL 23679, at *20 (1st Cir. 0000018840 00000 n
Oct. 21, 2005). 10-2240, 2012 WL 23679, at *20 (1st Cir. After decision on review by the Supreme Court, unless otherwise ordered by the Supreme Court under (3), a published opinion of a Court of Appeal in the matter, and any published opinion of a Court of Appeal in a matter in which the Supreme Court has ordered review and deferred action pending the decision, is citable and has binding or precedential effect, except to the extent it is inconsistent with the decision of the Supreme Court or is disapproved by that court. [8] See Circuit Rules 36-3; Fed. 0000035939 00000 n
Feb. 3, 2012). 0000006556 00000 n
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Indeed, persistent use of unpublished authority may be cause for sanctions. 05-CR-6050 CJS(W.D.N.Y. B. (8) Invokes a previously overlooked rule of law, or reaffirms a principle of law not applied in a recently reported decision; or Changes to decisions [4], The California standards for publication, and changes in publication status, are generally set out in California Rules of Court, rule 8.1105. endobj
Unpublished Opinion Logs by Case Name (Newest First) Search Unpublished Opinions. State names abbreviated with two single, adjacent capital letters (like N.Y. or S.C.) should not have a space between them and the district court. While the non-citation rule prohibits citation to any unpublished opinion, judicial notice pursuant to California Evidence Code section 452(d)(1) may be made as to the "[r]ecords of any court of this state . 25 0 obj <>
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(9) Is accompanied by a separate opinion concurring or dissenting on a legal issue, and publication of the majority and separate opinions would make a significant contribution to the development of the law. Subdivision (a). 2010). Services Corp. v. Superior Court (2002) 96 Cal.App.4th 443, 447, fn. Unpublished cases cited for compelling value are subject to these additional restrictions: (1) only cases issued on or after January 1, 2015, (2) no notice adequately addresses the matter in court, and (3) the citation does not refer to a published opinion or part of a statement. Federal Rule of Appellate Procedure 32.1 permits attorneys to cite to federal courts of ap-peals their unpublished opinions issued in 2007 or later. 2010). (8) Invokes a previously overlooked rule of law, or reaffirms a principle of law not applied in a recently reported decision; or
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In these instances, you cite to the case as published in one of theunofficial Supreme Court reporters, which are published more frequently: Supreme Court Reporter or United States Supreme Court Reports, Lawyers' Edition. (2) Applies an existing rule of law to a set of facts significantly different from those stated in published opinions; Local Rules and Appendices. Ct. R. 6. The difference between brief format and law review note format is mostly the typeface. To cite to a case in the United States Reports, list the following five elements in order: New York Times Co. v. Tasini, 533 U.S. 483 (2001). Federal Circuit Court of Appeals Cases First, the Committee decided to add federal before judicial opinions in subdivision (a) and before judicial opinion in subdivision (b) to make clear that Rule 32.1 applies only to the unpublished opinions of federal courts. Civil Action No. 0000005379 00000 n
P. 32.1 advisory committees note to 2006 adoption. Form of Briefs, Appendices, and Other Papers. Supp." United States Reports is an official publication of the United States Government, and is printed by the Government Printing Office. The Minnesota Court of Appeals does occasionally find its reasoning in unpublished opinions to have "persuasive" value, and accordingly may cite them. UNITED STATES OF AMERICA, )) Respondent. ) 0000001677 00000 n
Unlike the U.S. Supreme Court, cases from the federal courts of appeals are not compiled in an official reporter. Exceptions forunpublished/unreported opinions issued prior to2007 includeto establish the law of the case and if no published opinion would serve as well. Like the federal courts of appeals, cases from the federal district courts are not compiled in an official reporter. Such "unpublished" cases are ostensibly without value as precedent.However, the Supreme Court made a change to the Federal Rules of Appellate Procedure in 2006. While you will most often cite to cases in reporters, only a small percentage of cases are actually designated for publication by a court and published in a reporter. 0000000836 00000 n
Lawson v. FMR LLC, 571 U.S. 429 (2014). UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI . An opinion of a Court of Appeal or a superior court appellate division-whether it affirms or reverses a trial court order or judgment-should be certified for publication in the Official Reports if the opinion: (1) Establishes a new rule of law; at ___" (insert page number(s)). Decisions of the United States District Courtsare usually found in the: There is a space between the single capital letter F.and the longer abbreviationSupp. Rule 8.1115. See Assem. 2d"). Civil L.R. Com. Sentencing Submission Notice of the United States. Attorneys who appear in both state and federal courts must be familiar with the differences between the two systems. 0000030302 00000 n
Federal rules provide that federal courts must allow parties to citeunpublished (or unreported) opinions issued on or after January 1, 2007. Rule 32.1 is extremely limited. This refers to volume 400 of Massachusetts Reports, page 1 or volume 507 of Northeastern Reporter 2d, page 742. 0000016861 00000 n
See also Rule 10.3.1. placed on the citation of unpublished opinions[,] the Rules Advisory Committee for the Federal Rules of Appellate Procedure (FRAP) proposed that such restrictions be eliminated. 1995) (unpublished)). <>>>
When citing Supreme Court cases, you must cite to the official Supreme Court reporter, United States Reports. Georgetown University Law Library. A citation to a case in the United StatesReports includes the following five elements: You may need to include a "pinpoint" citation, which is a citation tothe page(s) on which the specific material referenced appears. Therefore, California opinions that are not citable in California state court are also not citable in the Northern District of California. 0000035560 00000 n
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Table 7 provides a list of explanatory phrases for prior and subsequent history. 0000013890 00000 n
Lawson v. FMR LLC, No. After decision on review by the Supreme Court, unless otherwise ordered by the Supreme Court under (3), a published opinion of a Court of Appeal in the matter, and any published opinion of a Court of Appeal in a matter in which the Supreme Court has ordered review and deferred action pending the decision, is citable and has binding or precedential effect, except to the extent it is inconsistent with the decision of the Supreme Court or is disapproved by that court. Proposed Local Rule Amendments. 22-6764. at the page number on which the material you citing to is located (at 115). For unpublished decisions from other states, each state's appellate rules must be reviewed to determine that state's citation rules. Appeals Court Reports, or the Northeastern Reporter. The federal district court opinion in theLawson v. FMRLLCcase is properly citedas: Lawson v. FMR LLC, 724 F.Supp. California has no rule prohibiting the citation of unpublished out-of-state or unpublished federal opinions. For example, the 9th Circuit is the federal circuit court for California, and the . CheckTable T.1 for guidance on how to cite to materials from such courts. Cummings Center for History of Psychology. 0000034910 00000 n
Passenger Co., 908 So. Rule 10.8.1 describes how to cite an unpublished case and there are examples in the chart at the beginning of Rule 10 (p. 95). For example, the recent case Arellano v. Mcdonoughis not available in the U.S. Reports yet (as of 2/14/2023). 2241 FOR A WRIT OF HABEAS CORPUS, ECF NO. Californias Electronic Discovery Act, enacted in 2009, was largely modeled on the federal rules. 2d and F. Supp. 2015). 0000016373 00000 n
In California state court, trial court opinions and unpublished California appellate opinions should not be cited. (e) When review of published opinion has been granted. The examples on this page are for practitioner citations (memos and briefs). United States Reportsis theofficialreporter of the Supreme Court, so you must citeto itwhen possible. [3] This includes trial court opinions, which are by their nature not published, and have no precedential value. The Petition is DISMISSED without prejudice, but without leave to amend, because Cacayorin failed to exhaust administrative . Subsequent citation forms should use a short form of the citation. Before 2016, a grant of review of an appellate opinion automatically depublished the opinion creating a minefield when looking to newly issued cases. Until it is available, the preferred unofficial reporter is theSupreme Court Reporter (S.Ct.) 2d 430 (2014). It is recommended that the format set out by the Supreme Court of Ohio Writing Manual be used when submitting briefs or other documents to Ohio State Courts. Subsequent citation forms should use a short form of the citation. Indeed, persistent use of unpublished authority may be cause for sanctions. Connecticut, Delaware, District of Columbia, Maine, Maryland, New Hampshire, New Jersey, Pennsylvania, Rhode Island, Vermont, Illinois, Indiana, Massachusetts, New York, Ohio, Iowa, Michigan, Minnesota, Nebraska, North Dakota, South Dakota, Wisconsin, Alaska, Arizona, California, Colorado, Hawaii, Idaho, Kansas, Montana, Nevada, New Mexico, Oklahoma, Oregon, Utah, Washington, Wyoming, Georgia, North Carolina, South Carolina, Virginia, West Virginia, Arkansas, Kentucky, Missouri, Texas, Tennessee. Rule 32.1 addresses only the citation of federal judicial dispositions that have been designated as unpublished or non-precedentialwhether or not those dispositions have been published in some way or are precedential in some sense. The Federal Appendix was a case law reporter published by West Publishing from 2001 to 2021. The links below will take you to the GPO website and search for the opinions as described. The local rules of the Central, Eastern, and Southern Districts of California do not forbid citation of unpublished cases. Any comments, suggestions, or requests to republish or adapt a guide should be submitted using the, https://guides.ll.georgetown.edu/bluebook, Name of the case (underlined or italicized and abbreviated according to Rule 10.2), Name of the court (abbreviated according to Rule 10.4), Date the case was decided, including month (Table 12), day, and year. 408.279.8700, Javascript must be enabled for the correct page display. It published judicial opinions of the United States courts of appeals that were not expressly selected or designated for publication. R. App. Rule 32.1(a) applies only to unpublished opinions issued on or after January 1, 2007. [6], In 2006, because federal courts differed dramatically with respect to the restrictions that they . Supp.) However, there is generally a significant lag between when the Court decides a case and when it is published in the United States Reports. as well as between the longer abbreviation Supp. 1.1 Delaware citation rules The Delaware courts have issued rules regarding proper citation form for documents filed in those courts. Medical Center v. Belshe (1997) 56 Cal.App.4th 819, 831; Alicia T. v. County of Los Angeles (1990) 222 Cal.App.3d 869, 884-85. Under Rule 32.1(b), a party who cites an opinion of a federal court must provide a copy of that opinion to the court of appeals and to the other parties, unless that opinion is available in a publicly accessible electronic databasesuch as a commercial database maintained by a legal research service or a database maintained by a court. 10-2240, 2012 U.S. App. opinions of the same court, although not precedent, may be cited for persuasive reasoning. [5] California Rules of Court, rule 8.1105 Publication of Appellate Opinions: All opinions of the Supreme Court are published in the Official Reports. This article, comparing the rules for citing unpublished authorities, is one of a five-part series of articles highlighting particular differences in California versus federal civil procedure. 2d [second series of the Federal Supplement]. Cacayorin v. Derr Filing 7 ORDER DISMISSING PETITION UNDER 28 U.S.C. An unpublished opinion may be cited or relied on: (1) When the opinion is relevant under the doctrines of law of the case, res judicata, or collateral estoppel; or (2) When the opinion is. Cal.] Department of Legal Affairs v. District Court of Appeal, Fifth Circuit, 434 So.2d 310 (Fla. 1983) (petition for mandamus to permit citation of unwritten opinions) Georgia Unreported decision is neither physical nor binding precedent Georgia Court of Factors such as the workload of the court, or the potential embarrassment of a litigant, lawyer, judge, or other person should not affect the determination of whether to publish an opinion. The short form of Roe v. Wade if Roe v. Wade was cited in the immediately preceding citation: Id. Aswith published/reported cases, you use Table 6 (case names), Table 7 (court names), and Table 10(geographical terms) for abbreviations. 0000001134 00000 n
Changes Made After Publication and Comment. (B) Grant of review by the Supreme Court of a decision by the Court of Appeal does not affect the appellate court's certification of the opinion for full or partial publication under rule 8.1105(b) or rule 8.1110, but any such Court of Appeal opinion, whether officially published in hard copy or electronically, must be accompanied by a prominent notation advising that review by the Supreme Court has been granted. Tyler represents plaintiffs and defendants in civil cases, public entity litigation, and high-stakes disputes. (d) When a published opinion may be cited. It begins with cases decided in 1880; pre-1880 cases were later retroactively compiled by West Publishing into a separate reporter, Federal Cases.The fourth and current Federal Reporter series publishes decisions of the United States . In some courts, those rules require Bluebook citation formats, for cases aswell as for other authorities. 7-14 or pursuant to a similar rule of any other issuing court, may not be cited to this Court, either in written submissions or oral argument, except when relevant under the doctrines of law of the case, res judicata or collateral estoppel.