Procedural history
Original research draft · October 2026
Working pattern
[Primary case], [citation], [accurate history phrase], [later decision citation].
Capture from the source
Both decisions; docket relationship; disposition; relevant issue
Check before you use it
Read the later disposition and verify that it concerns the decision cited.
Common error: An affirmance on another ground does not endorse every earlier rationale.
Completed example
Both courts, reports, decisions, issues, and docket relationships are fictional. No real appellate treatment or current validity determination is supplied by this example.
Mapletide Studio v. Solstice Press, 11 TRAIN Rep. 40, 46 (Northmere Trial Ct. 2024), affirmed on other grounds, 12 TRAIN Rep. 90 (Northmere Ct. App. 2025).
Read the supplied source facts
Fictional packet TRAIN-O12 contains Mapletide Studio v. Solstice Press, 11 TRAIN Rep. 40, decided by the fictional Northmere Trial Court in 2024, and its appeal at 12 TRAIN Rep. 90 in the fictional Northmere Court of Appeals in 2025. The appellate caption and docket cross-reference match the trial proceeding. The appellate disposition affirms the judgment on a timeliness ground while expressly declining to consider the trial court's interpretation of the delivery clause. The draft cites trial page 46 for that interpretation and labels the appeal a complete endorsement.
Why this works
The history phrase describes the relationship shown by the supplied appellate disposition. It does not turn the trial court's contract analysis into an appellate holding. Correct the surrounding prose to acknowledge the limitation: the appellate court affirmed the judgment on a different ground and left that interpretation unaddressed. Verify the relationship from the docket and opinion, because similar party names can occur in separate proceedings. Preserve the later decision's disposition and the issue it reached as distinct research fields. A history abbreviation is a compact description of an event, not a substitute for analyzing what survived review.
When the facts change
If the later disposition instead vacated only a fee award while leaving the merits judgment intact, a blanket vacated label would be misleading. Identify the affected part and, when necessary, describe the limited disposition in prose. If a later proceeding involves a different order in the same litigation, explain that connection rather than attaching it as though it reviewed the decision cited.
Apply the receiving court or publication’s requirements. These working forms do not establish citation permission, precedential weight, or support for a legal proposition.