 "Unpublished" decisions handed down after 1980 are generally available through the LexisNexis and Westlaw databases, but are useful only for academic researchers or as an aid in finding relevant published decisions.An unpublished decision in a criminal or civil action generally cannot be cited in any other action in any California court.Because the state supreme court was extremely overloaded with cases during its first half-century (resulting in the creation of the Courts of Appeal in 1904), a few hundred minor opinions that "should" have been published simply were not.