Memorandum Appellate Decisions Can be Cited Beginning 2023

Written By Cara Wieneke

Yesterday the Supreme Court of Indiana amended Indiana Appellate Rule 65 to allow parties to cite to memorandum (i.e., unpublished) appellate decisions issued on or after January 1, 2023. These decisions are persuasive only; they are not binding on any court. The language for the amended rule can be found here.

The Bluebook directs parties to cite unpublished decisions as follows:

Party v. Party, No. 23-1111, 2023 WL 11111, at *1-2 (Ind. Mar. 1, 2023).

Cara Wieneke
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