You can go along with everything from a sleeveless dress to one that's even strapless to a long-sleeved or short-sleeved gown.
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Neither a daytime event nor a proper summer evening soiree requires a full-length gown.
If the mom of the bride selects a more casual and laid-back look, more than likely permitted by the bride herself, then the groom’s mother in all probability won’t need to select an excessively formal costume.