Portable authority
A proposition that may be cited across procedural stages because it would remain true on any record, such as an element definition or a substantive rule of law, as opposed to a sufficiency holding that reports how a standard applied to particular material.
First used in Right Law, Wrong Stage
The carry-across rule answers the practical question behind posture mismatch: can a summary judgment case be cited in a motion to dismiss? Yes, but only for propositions that do not depend on the summary judgment record or standard.
Element definitions, substantive rules of law, and questions of statutory or contractual construction decided as a matter of law usually carry. Sufficiency holdings do not. An intermediate class, holdings phrased as sufficiency but resting on a rule of law (a kind of fact that cannot establish an element even if proven), carries when cited for the rule and not for the record.
The test is one question: would the proposition remain true if the record were different? If so, it may travel. The working draft of the argument named the two sides of this line portable and non-portable authority.