- an incidental or passing remark, opinion, etc.
- an incidental or supplementary opinion by a judge in deciding a case, upon a matter not essential to the decision, and therefore not binding as precedent.
- an observation by a judge on some point of law not directly in issue in the case before him and thus neither requiring his decision nor serving as a precedent, but nevertheless of persuasive authority
- any comment, remark, or observation made in passing