In 2017, the Pennsylvania judiciary enacted Pa. R.A.P. 126(2), which finally rendered unpublished Pennsylvania Superior Court decisions citable in state-court briefing. I discussed it at the time (see “Appellate Notes”). That amendment was supposed to put an end to citational gamesmanship with respect to unpublished Superior Court decisions, which were largely available only to lawyers who paid for access to online reporting services. However, new Rule 126(2) only applied to memorandum decisions issued “after May 1, 2019.” See also Super. Ct. I.O.P. Section 65.37 (“An unpublished memorandum decision filed prior to May 2, 2019, shall not be relied upon or cited by a court or a party in any other action or proceeding, except in special circumstances.”).