Right law at the wrong stage is wrong law.

Every holding is announced under a standard: a test applied to a defined body of material, with the burden on a particular party, in a particular forum. Detached from that standard, a holding does not become a more general rule. It becomes a different proposition, one the deciding court never decided.

Posture mismatch comes in four kinds. Standard mismatch: a motion to dismiss asks whether allegations state a plausible claim, while summary judgment asks whether there is a genuine dispute of material fact. Record mismatch: a case saying the plaintiff "offered no evidence" describes a record, and cited in a motion confined to the pleadings it asserts something the movant cannot establish at that stage. Burden mismatch: the federal Celotex route lets a movant point to an absence of evidence, while under Aguilar v. Atlantic Richfield Co. a California defendant must still present evidence. Forum mismatch: Twombly and Iqbal construe a federal rule and do not govern a California demurrer, which asks whether the complaint states facts sufficient to constitute a cause of action.

A citator flags none of these, because nothing in the cited case's later history has changed. The flag is green and the citation is still wrong.

One question separates safe from unsafe uses: would the proposition remain true if the record were different? Element definitions and pure rules of law usually travel across stages. Sufficiency holdings, which report how a standard applied to particular material, do not. Telling a tool never to cite summary judgment cases in a motion to dismiss is both too broad and too narrow. The right instruction is to cite across stages only for propositions that do not depend on the other stage's record or standard.