Rule 32.1. Howard Bashman, of How Appealing fame, has written an article on an attempt by opponents of proposed Rule 32.1 of the Federal Rules of Appellate Procedure, which would allow for the citation of "unpublished" opinions, to limit the effect of the rule by making the rule applicable only to such decisions issued after January 1, 2007. His article (on Law.com) can be found here.