In Sullivan v. Little Hunting Park, Inc. (1969) 396 U.S. 229, a Virginia State court rule requiring "reasonable written notice of the time and place of tendering a transcript" was deemed by the United States Supreme Court to be a discretionary, rather than a jurisdictional, rule because of its inconsistent application; thus, review by certiorari of discriminatory bylaws of a corporation was not barred. (Sullivan, supra, 396 U.S. at pages 231-234.)