Under United States legal practice, a memorandum opinion is usually unpublished and cannot be cited as precedent.
It is formally defined as: "[a] unanimous appellate opinion that succinctly states the decision of the court; an opinion that briefly reports the court's conclusion, usu.
without elaboration because the decision follows a well-established legal principle or does not relate to any point of law.
However, in many courts (for example, the Appellate Division of the Supreme Court of New York), the style of analysis in memorandum opinions is much more concise and conclusory than it would be in an opinion intended for publication.
[2] Nonetheless, the Courts of Appeal have the discretion not to certify opinions in frivolous cases for publication.