Anyone have an opinion on how to best cite the latest opinions from the Thirteenth Court of Appeals. While I am unsure from whence its opinions are actually issued, they now show the location for the court to be "Corpus Christi-Edinburg". Does that mean the proper citation is Lemoine v. State, 85 S.W.3d 385 (Tex.App.-- Corpus Christi-Edinburg 2002)?
My Green Book (Texas Rules of Form) refers to the 13th Court as "Corpus Christi". (P. 21).
Until the C.J. of the 13th tells me differently, the C.J. of my court tells me differently, either C.J. Phillips or P.J. Keller (of the really big courts) tells me differently, or until Texas Law Review changes its rules, I'll call the 13th "Corpus Christi".
That being said, it's been my experience that appellate judges are more concerned that the case you're citing is valid authority for your point than whether you've mastered the finite points of Blue book, Green book, or Maroon book (any Chicago grads out there?) form.
My advice: be consistent in citation of the law, but more importantly be accurate in your application of the law.
Maybe the new form of citation applies only in footnotes (since that is the only place it has appeared so far in court opinions), but now a high court has "spoken"? See Simms, 127 S.W.3d 924, fn. 3; Ortega, No. 819-04 CCA (09/14/05) in fn. 1.
