Washington State Court of Appeals: State v. Butler Document Filed

designation carries significant implications for legal practitioners within the Ninth Circuit, as it means the decision, while binding on the parties involved, cannot be cited as precedential authority by other courts or parties in unrelated matters. This practice is a common mechanism used by appellate courts to manage the volume of published opinions, reserving precedential status for cases that establish new legal principles or significantly alter existing ones, thereby preventing the proliferation of opinions that merely apply settled law to specific facts. For attorneys, understanding this distinction is crucial for effective legal research and argument construction.

The legal context for this filing is rooted in the Federal Rules of Appellate Procedure and the Ninth Circuit's local rules, specifically Federal Rule of Appellate Procedure 32.1 and Ninth Circuit Rule 36-3. While FRAP 32.1 generally permits the citation of unpublished opinions issued on or after January 1, 2007, Ninth Circuit Rule 36-3 imposes stricter limitations, allowing citation only in narrow circumstances such as establishing res judicata, collateral estoppel, or the law of the case, or when there is no published opinion that would serve as well. The case number, 25-5543, suggests the appeal was initiated in 2025. The excerpt does not provide any details regarding the nature of the dispute, the specific legal issues addressed, or the outcome of the court's review.

The key parties involved in this appellate matter are Pelisi Foketi Fonua and Blanche, with the United States Court of Appeals for the Ninth Circuit serving as the adjudicating body. Molly C. Dwyer is identified as the Clerk of the U.S. Court of Appeals for the Ninth Circuit, responsible for the administrative filing of court documents. The excerpt does not specify the roles of Fonua or Blanche (e.g., appellant or appellee) or the underlying facts of the case.

Practitioners in the Ninth Circuit must meticulously note the "NOT FOR PUBLICATION" status of this filing. This means that while the resolution of *Fonua v. Blanche* is final for the litigants, it does not contribute to the body of binding legal precedent. Attorneys should therefore refrain from citing this case as persuasive authority in other proceedings unless it falls squarely within the limited exceptions for preclusion or law of the case, as outlined in Ninth Circuit Rule 36-3. It is imperative to always verify the publication status of any Ninth Circuit decision before relying on it in legal arguments, as improper citation can lead to sanctions or undermine the credibility of legal submissions. The specific details of the ruling or the underlying facts are not reported in the excerpt, so practitioners cannot glean substantive legal guidance from this filing alone.