Petition for Writ of Certiorari — Trevon Wiley, Petitioner v. Louisiana

Supreme Court briefApr 5, 2021

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OFFICE OF THE CLERK

IN THE

SUPREME COURT OF THE UNITED STATES

TREVON WILEY — PETITIONER

vs.

DARREL VANNOY, WARDEN — RESPONDENT(S)

ON PETITION FOR A WRIT OF CERTIORARI TO

THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT

PETITION FOR WRIT OF CERTIORARI

TREVON WILEY

557602, CYPRESS—3

LOUISIANA STATE PENITENTIARY

ANGOLA, LA 70712

QUESTION PRESENTED

This case also involves 2 non-unanimous verdicts leading to the

following question:

Does the Court’s decision in Ramos v. Louisiana, 140 S.Ct. 1390

(2020) applies to cases on state collateral review, where the State follows

the retroactivity framework established in Teague v. Lane, 489 U.S. 288

(1989)?

LIST OF PARTIES

All parties appear in the cation of the case on the cover page.

111

TABLE OF CONTENTS

PAGE NO.

QUESTIONS PRESENTED

.11

LIST OF PARTIES

TABLE OF CONTENTS

INDEX TO APPENDICES

TABLE OF CITED AUTHORITIES

OPINIONS BELOW

JURISDICTION

CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED

STATEMENT OF THE CASE

REASONS FOR GRANTING THE WRIT

Wiley’s non-unanimous convictions violates the dictates of the Sixth

and Fourteenth Amendments to the United States Constitution, this

Court’s holding in Ramos v. Louisiana, and nearly every tenet of

fundamental fairness, substantial justice, due process, equal protection

and reasonable doubt.

The Sixth Amendment Demands Unanimity in State and Federal

Trials................................................................................................ 7

Ramos Is Not New Law as Apodaca had no Precedential Effect.... 13

CONCLUSION

INDEX TO APPENDICES

Appendix

Page

Louisiana Supreme Court’s March 23, 2021, Denial of

Post-Conviction Relief

Fifth Circuit Court of Appeal’s Denial of Post-Conviction

Relief

Twenty-fourth Judicial District Court’s Denial of PostConviction Relief

Application for Writ of Certiorari to the Louisiana

Supreme Court

Application for Supervisory Writ of Review to Fifth

Circuit of Appeal

Application for Post-Conviction Relief with Memorandum

in Support

Transcript of Jury Polling Results

TABLE OF AUTHORITIES CITED

CASES

PAGE NUMBER

Andres v. United States, 333 U.S. 740, 68 S.Ct. 880 (1948)

7,15

Apodaca v. Oregon, 406 U.S. 404, 92 S.Ct. 1628 (1971).........

passim

Apprendi v. New Jersey, 530 U.S. 466, 120 S.Ct. 2348 (2000)

8,16

Brown v. Louisiana, 447 U.S. 323, 100 S.Ct. 2214 (1980)

Descamps v. United States, 570 U.S. 254, 133 S.Ct. 2276 (2013)

Duncan v. Louisiana, 391 U.S. 145, 88 S.Ct. 144 (1968)

Edwards v. Vannoy,

S.Ct.___(2020) (No. 19-5807)

Johnson v. Louisiana, 406 U.S. 356, 92 S.Ct. 1620 (1971)

4,17

8,9,11,15

Maxwell v. Dow, 176 U.S. 581 (1900)

McDonald v. City of Chicago, 130 S.Ct. 3020, 561 U.S. 742 (2010).

Patton v. United States, 281 U.S. 276 (1930)

Ramos v. Louisiana, 140 S.Ct. 1390 (2020).

passim

State v. Wiley, 10-811 (La. App. 5 Cir. 4/26/11); 68 So.3d 583

State v. Wiley, 2011-1263 (La. 3/30/12); 85 So.3d 106

Teague v. Lane, 489 U.S. 288, 109 S.Ct. 1060 (1989)

5,13,17

Timbs v. Indiana, 139 S.Ct. 682 (2019)

Thompson v. Utah, 170 U.S. 343, 18 S.Ct. 620 (1898)

7,14

Williams v. Florida, 399 U.S. 78, 90 S.Ct. 1893 (1970)

STATUTES AND RULES

28U.S.C. § 1257(a)

Rule 10 of the United States Supreme Court

Yll

IN THE

SUPREME COURT OF THE UNITED STATES

PETITION FOR WRIT OF CERTIORARI

Petitioner, Trevon Wiley, respectfully petitions for a writ of certiorari

to review the judgment of the Louisiana Supreme Court.

OPINIONS BELOW

The Louisiana Supreme Court’s decision to deny Wiley’s application

for a writ of certiorari is published at 2020-01327 (La. 3/23/21); — So.3d

— 2021 WL 1113550 and appears at Appendix A. The Fifth Circuit Court of

Appeal’s decision is unpublished but appears at Appendix B. The TwentyFourth Judicial District Court’s decision is unpublished but appears at

Appendix C.

JURISDICTION

The Louisiana Supreme Court denied discretionary review of Wiley’s

application for a writ of certiorari on March 23, 2021. The Court’s

jurisdiction is invoked under 28 U.S.C. § 1257(a).

CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED

The Sixth Amendment to the United Sates Constitution provides in

pertinent part:

In all criminal prosecutions, the accused shall enjoy the right to a

speedy and public trial, by an impartial jury ... and to have the

assistance of counsel for his defense.

The Fourteenth Amendment to the United Sates Constitution provides

in pertinent part:

No State shall make or enforce any law which shall abridge the

privileges or immunities of citizens of the United States; nor

shall any State deprive any person of life, liberty, or property,

without due process of law; nor deny to any person within its

jurisdiction the equal protection of the laws.

La. C. Cr. P. art. 930.3

If the petitioner is in custody after sentence for conviction for an

offense, relief shall be granted only on the following grounds:

(1) The conviction was obtained in violation of the constitution

of the United States or the state of Louisiana.

STATEMENT OF THE CASE

On August 19, 2009, Wiley was convicted by a 10-to-2 verdict of second

degree murder and by an 11-to- l verdict of aggravated burglary. On August

31, 2009, the trial court imposed a life without benefits sentence and a

concurrent, and maximum, thirty-year sentence. On April 26, 2011, the Fifth

Circuit Court of Appeal affirmed Wiley’s conviction but remanded for

resentencing to remove the trial court’s unlawful flat-time stipulation. State

v. Wiley, 10-811 (La. App. 5 Cir. 4/26/11); 68 So.3d 583. On March 30, 2012,

the Louisiana Supreme Court declined to invoke its supervisory jurisdiction.

State v. Wiley, 2011-1263 (La. 3/30/12); 85 So.3d 106.

Wiley filed an application for post-conviction relief and argued that his

non-unanimous jury verdicts violated his Sixth Amendment right to a jury

trial as described and affirmed by the Court in Ramos v. Louisiana, 140 S.Ct.

1390 (2020). On August 3, 2020, the trial court issued a one-page ruling

denying Wiley’s application for post-conviction relief. In fact, the trial court

said the “Ramos decision affects [only] cases not yet final. The Supreme

Court emphasized that ‘the Court’s decision today will invalidate some nonunanimous convictions where the issue is preserved and the case is still on

direct review. ’ The petitioner is not on direct review.” Appendix C, p. 5.

In upholding the trial court’s ruling, the appellate court said: “Ramos

v. Louisiana holds that the Sixth Amendment right to a jury trial—as

incorporated against the states by the Fourteenth Amendment—requires a

unanimous verdict to convict a defendant of a serious offense... .To date, the

Louisiana Supreme Court has not held that Ramos v. Louisiana should be

given retroactive application.” Appendix B, p. 3. This instant petition for a

writ of certiorari timely follows.

REASONS FOR GRANTING AND STAYING THE WRIT

On May 4, 2020, the Court granted a petition for a writ of certiorari in

Edwards v. Vannoy,

S.Ct.___(2020) (No. 19-5807) to determine if the

decision in Ramos v. Louisiana, 140 S.Ct. 1390 (2020) applies retroactively

to petitioners whose convictions were final when Ramos was decided. Wiley

respectfully asks the Court to stay this petition pending the resolution of

Edwards v. Vannoy and then dispose of the petition as appropriate in light of

that decision.

Wiley’s matter involves his 2009 felony convictions based on 2 nonunanimous jury verdicts. Wiley’s case is appropriate for review because it

involves a significant unresolved issue of law on collateral cases and because

the Louisiana courts have erroneously interpreted or applied the relevant law.

Wiley’s non-unanimous jury verdict should be reversed as Ramos v.

Louisiana did not announce a new rule subject to retroactivity analysis, but

rather clarified and corrected the erroneous reasoning presented in Apodaca v.

Oregon, 406 U.S. 404, 92 S.Ct. 1628, 62 L.Ed.2d 152 (1971). Unanimous

jury verdicts have been the mainstay of the American system of law since the

Founding. Apodaca was an outlier, its peculiar plurality opinion, along with

its utterly repudiated “dual tract” doctrine, did not have any binding effect on

the lower courts. Alternatively, even utilizing retroactivity analysis, the

Ramos decision clearly meets the criteria announced in Teague v. Lane, 489

U.S. 288, 109 S.Ct. 1060, 103 L.Ed.2d334 (1989). It represents a watershed

rule that implicates the fundamental fairness and accuracy of criminal

prosecutions. As this honorable Court noted: “It is difficult to envision a

constitutional rule that more fundamentally implicates the fairness of the trial

—the very integrity of the fact-finding process.... It’s purpose, therefore,

clearly requires retroactive application.” Brown v. Louisiana, 447 U.S. 323,

100 S.Ct. 2214, 65 L.Ed.2d 189 (1980). Finally, the State can evince no

cogent basis upon which to rely on the finality of non-unanimous verdicts,

the very establishment of which has always and unabashedly been premised

on racial animus. As this Court said in Ramos: “[I]t is something else entirely

to perpetuate something we all know to be wrong only because we fear the

consequences of being right.”

Wiley’s non-unanimous convictions violates the dictates of the

Sixth and Fourteenth Amendments to the United States

Constitution, this Court’s holding in Ramos v. Louisiana, and

nearly every tenet of fundamental fairness, substantial justice,

due process, equal protection and reasonable doubt.

Twelve men and women served on Wiley’s petit jury. Twelve jurors

culled from hundreds of potential jurors who answered the call for service.

The jurors were selected after vigorous questioning by the trial court, the

State, and the Defense. They were educated on the rudiments and fundamentals

of the law during voir dire, the court’s opening remarks and final

instructions. Throughout the process, the parties and the court certified that

each member of the jury was a reasonable person, qualified by their

education, experience and common sense to render judgment for or against

Wiley; and yet, 2 jurors found room to doubt his guilt and the State’s case

against him. When reasonable persons can harbor doubts, those doubts are

likewise reasonable. Thus Wiley was not convicted beyond reasonable

doubt. He was convicted with doubt entrenched in the mind of at least 2

members of his jury with regards to the second degree murder charge and 1

juror concerning the aggravated burglary. Wiley’s non-unanimous jury

verdicts, and the rejection of his right to be convicted beyond a reasonable

doubt, violated his Sixth and Fourteenth Amendment due process and equal

protection rights to a jury trial.

The Sixth Amendment Demands Unanimity in State and Federal

Trials.

The Sixth Amendment to the United States Constitution guarantees

unanimity in federal criminal jury trials Andres v. United Slates, 333 U.S.

740, 68 S.Ct. 880, 92 L.Ed. 1055 (1948). “[T]he wise men who framed the

constitution of the United States and the people who approved it were of the

opinion that life and liberty, when involved in criminal prosecutions, would

not be adequately secured except through the unanimous verdict of twelve

jurors.” Thompson v. Utah, 170 U.S. 343, 18 S.Ct. 620, 42 L.Ed. 1061 (1898)

(“It was not for the state, in respect of a crime committed within its limits

while it was a territory, to dispense with that guaranty simply because its

people had reached the conclusion that the truth could be well ascertained,

and the liberty of an accused be as well guarded, by eight as by twelve jurors

in a criminal case.”) The unanimity requirement extends to all issues,

including the character or degree of the crime, guilt and punishment, which

are left to the jury. Id. A jury trial has historically been understood to require

“the truth of every accusation, whether preferred in the shape of indictment,

information, or appeal, should afterwards be confirmed by the unanimous

suffrage of twelve of [the defendant’s] equals and neighbors [sic]...”

Apprendi v. New Jersey, 530 U.S. 466, 120 S.Ct. 2348, 147 L.Ed.2d 435

(2000); citing Blackstone.

Nevertheless, while the Fourteenth Amendment’s due process clause

guarantees the right to a jury trial, jury unanimity has remained an outlier.

Duncan v. Louisiana, 391 U.S. 145, 88 S.Ct. 144, 20 L.Ed.2d491 (1968).

This honorable Court has said that “the States are free under the Federal

Constitution to try defendants with juries of less than 12 men.” Williams v.

Florida, 399 U.S. 78, 90 S.Ct. 1893, 26 L.Ed.2d446 (1970); citing Johnson

v. Louisiana, 406 U.S. 356, 92 S.Ct. 1620, 32 L.Ed.2d 152 (1971).

The seminal case for non-unanimous jury verdicts is Apodaca v.

Oregon, 406 U.S. 404, 92 S.Ct. 1628, 62 L.Ed.2d 152 (1971). In Apodaca, a

bitterly divided court eschewed the historical context and a nearly unbroken

chain of cases recognizing unanimity, instead “focus[ing] upon the function

served by the jury in contemporary society.” Id., at 410.

£[T]he essential feature of a jury obviously lies in the

interposition between the accused and his accuser of the

commonsense judgment of a group of laymen... ’ A requirement

of unanimity, however, does not materially contribute to the

exercise of this commonsense judgment... .In terms of this

function we perceive no difference between juries required to act

unanimously and those permitted to convict or acquit by votes of

10 to two or 11 to one. Requiring unanimity would obviously

produce hung juries in some situations where nonunanimous

juries will convict or acquit. But in either case, the interest of

the defendant in having the judgment of his peers interposed

between himself and the officers of the State who prosecute mid

judge him is equally well served.

Apodacav. Oregon, at 410-11.

The Apodaca Court’s ruling is a peculiar aberration. First, 8 members

of the Apodaca Court held that the Sixth Amendment applied equally to the

states and the federal government. Johnson v. Louisiana, 406 U.S., at 395-96.

Only Justice Powell rejected the prior precedent and cast the decisive vote

to conclude that the Sixth Amendment did not apply to the states in the same

way it applied to the federal government. Second, this Court’s due process

jurisprudence has long held that the Sixth Amendment’s jury trial guarantee

applies to the states and that, where a Bill of Rights protection is incorporated

in the Fourteenth Amendment, “there is no daylight between the federal and

state conduct it prohibits or requires.” Timbsv. Indiana, 139 S.Ct. 682, 203

L.Ed.2d 11 (2019). This Court has also said it would be “incongruous” to

apply different standards “depending on whether the claim was asserted in a

state or federal court.” McDonald v. City of Chicago, 130 S.Ct. 3020, 561

U.S. 742, 177 L.Ed.2d 894 (2010). Consequently, this Court’s own authority

undermined Justice Powell’s deciding vote and rationale in Apodaca.

That the right to trial by jury is fundamental and applies to the states

through the Fourteenth Amendment’s due process clause is undisputed. It is

also settled Supreme Court jurisprudence that rights incorporated by the

Fourteenth Amendment received identical treatment by both the states and

the federal government. These inviolable principles were recently reaffirmed

in Ramos v. Lomsianay 140 S.Ct. 1390 (2020).

In Ramos, this honorable Court held that there is no colorable doubt

what the Framer’s of the Constitution had in mind when they enshrined the

right to trial by jury. “Wherever we might look to determine what the term

‘trial by an impartial jury trial’ meant at the time of the Sixth Amendment’s

adoption ... the answer is unmistakable. A jury must reach a unanimous

verdict in order to convict.” Idy at *4. Next the Court held that longstanding

jurisprudence holds that, where an amendment has been held to apply to the

states through the Fourteenth Amendment, the Bill of Rights must be

enforced the same for the federal government and the states, there can be no

“daylight” between the protections of the one and the other:

There can be no question either that the Sixth Amendment’s

unanimity requirement applies to state and federal criminal trials

equally. This Court has long explained that the Sixth Amendment

right to a jury trial is “fundamental to the American scheme of

justice” and incorporated against the States under the Fourteenth

Amendment. This Court has long explained, too, that incorporated

provisions of the Bill of Rights bear the same content when

asserted against States as they do when asserted against the

federal government. So, if the Sixth Amendment’s right to a jury

trial requires a unanimous verdict to support a conviction in

federal court, it requires no less in state court.

Ramos v. Louisiana, at *7.

Having determined that the right by trial implicates a unanimous jury

verdict and that the right applies with equal force to the federal government

and the states, the Ramos Court spent the bulk of its opinion evaluating the

Apodaca opinion. Apodaca was heard in tandem with Johnson v. Louisiana,

and both cases challenged non-unanimous jury statutes. Apodaca was a split

decision; even so, all 9 Justices found that the Sixth Amendment originally

required unanimity. However, 4 of the Justices believed that “unanimity’s

costs outweighjed] its benefits in the modem era.” Therefore, they were

willing to uphold non-unanimous verdicts in state courts. Justice Powell cast

the deciding vote. Failing to align with either side’s version, he argued that

the Sixth Amendment required unanimous jury verdicts only in federal courts.

This so-called “dual track” theory holds that different standards of

constitutional protections apply to the state and federal governments and, as

such, they must be evaluated differently.

However, as the Court made clear in Ramos, Justice Powell’s dual

track argument had already been rejected: “The Court had already, nearly a

decade earlier, rejected the notion that the Fourteenth Amendment applies to

the States only a watered-down, subjective version of the individual

guarantees of the Bill of Rights.” Ramos, supra at *9 (internal quotations

omitted). Consequently, the Ramos majority was thus faced with a dilemma.

Apodaca should have precedential effects, but the decision was deeply

flawed because: (a) all the justices agreed that the Sixth Amendment

provided a right to a unanimous jury verdict; (b) no majority of the Court

authored the controlling opinion; and (c) Justice Powell’s opinion—which

gave the majority its votes—was based upon grounds that were already

invalid at the time of the opinion:

[N]ot even Louisianatri.es to suggest that Apodoca supplies a

governing precedent. Remember, Justice Powell agreed that the

Sixth Amendment requires a unanimous verdict to convict, so he

would have no objection to that aspect of our holding today.

Justice Powell reached a different result only by relying on a

dual-track theory of incorporation that a majority of the Court

had already rejected [and continues to reject].

Id., at p. *16 (emphasis added).

Moreover, even if the Court “accepted the premise that Apodaca

established a precedent, no one on the Court today is prepared to say it was

rightly decided, and stare decisis isn’t supposed to be the art of

methodically ignoring what everyone knows to be true.” Id., at p. *20.

Properly read, Ramos does not overrule Apodaca-, it merely recognized

that the decision never had precedential effect. It was never the law of the

land and any non-unanimous conviction upheld under its premises is

phantasmic. That the Sixth Amendment provides for unanimous jury

verdicts is not now—and never has been—a real dispute. In Apodaca, all of

the Justices agreed that unanimity was required at the Founding. 4 Justices,

however, would do away with it as “too burdensome.” A fifth, Justice

Powell, would argue that the right to a unanimous jury verdict was essential

to federal trials but did not apply to the states through the Fourteenth

Amendment. As the Ramos Court noted, Justice Powell’s view of “dual

track theory of incorporation was already foreclosed in 1972.”

Ramos Is Not New Law as Apodaca had no Precedential Effect.

The Ramos majority is clear—the decision is not retroactive. That is,

the Court only heard the limited issue of whether the Sixth Amendment’s

right to unanimity applies to the states: “[Tjhe Teague question [is not] even

before us. Whether the right to jury unanimity applies to cases on collateral

review is a question for a future case where the parties will have a chance to

brief the issue and we will benefit from their adversarial presentation.”

Ramos, supra at *12. In Ramos, this honorable Court pointed out that the

right to unanimous jury verdicts originated in Fourteenth century England

and had been practiced for four-hundred years by the time of the Founding.

The right was widely practiced both before mid after the Revolution and has

remained a stalwart feature of constitutional jurisprudence ever since. The

Apodaca decision, the sole support for non-unanimous verdicts, was flawed,

fractured, and Justice Powell’s deciding vote violated decades of Supreme

Court precedent in its attempt to revive the ersatz “dual tract” doctrine. Here

the Court made a strong argument that Apodaca was not worth the paper it

was written on and that it never had precedential authority.

This honorable Supreme Court has issued no fewer than fourteen

opinions holding that the Sixth Amendment requires unanimous verdicts to

convict. In 1898, the Court held that “life and liberty, when involved in

criminal prosecutions, would not be adequately secured except through the

unanimous verdict of twelve jurors.” Thompson v. Utah, 170 U.S. 343, 18

S.Ct. 620. The Court followed in short order with several similar opinions.

See generally, Maxwell v. Dow, 176 U.S. 581, 586 (1900); Patton v. United

States, 281 U.S. 276, 288 (1930). In 1942, again emphasizing the Sixth

Amendment’s demand for“[u]nanimity injury verdicts,” the Court extended

the requirement “upon both guilt and whether the punishment of death

should be imposed.” Andres, supra.

Even in Apodaca v. Oregon a majority of the Court agreed that the

Sixth Amendment requires jury unanimity to convict. Justice Powell

accepted the “unbroken line of cases reaching back into the late 1800’s”

holding that, under the Sixth Amendment, “unanimity is one of the

indispensable features of federal jury trial[s].” Johnson, supra at 369.

Justice Stewart, writing for 3 Justices, also concluded that “the Sixth

Amendment’s guarantee of trial by jury embraces a guarantee that the

verdict of the jury must be unanimous.” Apodaca, supra at 414-15. Justice

Douglas similarly maintained that “the federal Constitution re quire [s] a

unanimous jury in all criminal cases.” Johnson, supra at 382.

Since Apodaca, this Court has continued to recognize that the Sixth

Amendment requires that “the truth of every accusation ... be confirmed by

the unanimous suffrage of twelve of [a defendant’s] equals and neighbors”

and “contemplates that a jury ... [will find the essential facts] unanimously

and beyond a reasonable doubt.” Apprendi, supra at 477; Descamps v.

United States, 570 U.S. 254, 133 S.Ct. 2276, 186 L.Ed.2d438 (2013).

A close reading of Ramos suggests that in attempting to circumscribe

the Court’s previous authority, the Apodaca Court in general (and Justice

Powell in particular) rendered an opinion without precedential authority. As

this Court noted in Ramos, Justice Powell “agreed that the Sixth Amendment

requires a unanimous verdict to convict.” Ramos, supra at *16. This is

uncontested. In voting with the majority, however, Justice Powell relied

upon the “dual-track theory,” an interpretation of law that was, and

continues to be, invalid. 1 Justice cannot overrule precedent:

It is usually a judicial decision’s reasoning—its ratio decidendi

—that allows it to have life and effect in the disposition of

future cases. As this Court has repeatedly explained in the

context of summary affirmances, “unexplicated” decisions may

csettl[e] the issues for parties, [but they are] not to be read as a

renunciation by this Court of doctrines previously announced in

our opinions.” Much the same may be said here. Apodaca’s

judgment line resolved that case for the parties in that case. It is

binding in that sense. But stripped from any reasoning, its

judgment alone cannot be read to repudiate this Court’s repeated

pre-existing teachings on the Sixth and Fourteenth Amendments.

Id., atp. *“24.

Put another way, since all 9 Justices recognized the requirement of

unanimity at the time of the Framing and since Justice Powell’s majority-

deciding vote sought to resurrect the previously-rejected theory of divergent

construction of constitutional principles at the state and federal level, the

Apodaca ruling was valid only in the case before the Court: “[Stripped

from any reasoning, its judgment alone cannot be read to repudiate this

Court’s repeated pre-existing teachings on the Sixth and Fourteenth

Amendments.” Id Accordingly, the Teague analysis is not, strictly speaking

required, as the Sixth Amendment does—and always has—barred the non

un animous verdicts found acceptable in only 2 jurisdictions in the nation—

Louisiana and Oregon. Accordingly, Wiley is entitled to the reversal of his

convictions.

CONCLUSION

For the foregoing reasons Wiley’s petition for a writ of certiorari

should be granted and held in abeyance pending this Court’s decision in

Edwards v. Vannoy,

S.Ct.___(2020) (No. 19-5807) and then be

disposed of as appropriate in light of that decision.

Respectfully submitted,

•Om

Trevon Wiley

Date: April 5, 2021

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.