Capitalize the state as a party or actor

Warning²Federal courts, Illinois courts21st and 22nd editions

“State” and “Commonwealth” take a capital where the word names the government itself acting or litigating, as in “the State brought this action”.¹

1. 1R. 8(d)(ii) Exceptions; R. 8(c)(ii) Exceptions.
2. 2A warning: the form is usually wrong under the rule in note 1, and context can justify it.