Sample Briefs

Briefs in the Texas Supreme Court

Winning advocacy in the Texas Supreme Court requires a focus on what motivates the Court to exercise its discretion to accept, or to deny, review.

As Petitioner.  This petition for review  in NCAA v. Yeo asked the Court to hear a constitutional case about college athletics. (The Court granted, reversed, and rendered.)

As Respondent.  This response to a petition  in Hole v. Texas A&M University ended a long-running and contentious case without the need for full briefing.

On Rehearing.  My motion for rehearing  in State v. Precision Solar Controls was used as an example at an advanced appellate course. (The Court granted rehearing.)

As Amicus Curiae. This amicus brief  urging rehearing in Reata Construction v. City of Dallas set out the State's position about a landmark sovereign immunity decision. (The Court granted rehearing and modified its original holding.)

Briefs to the Fifth Circuit

Merits Briefs.  This merits brief  in Allstate v. Abbott defended a Texas law prohibiting insurance companies from integrating into the autobody-repair business.

Interlocutory Appeal.  This petition for permission  to file an interlocutory appeal in Equal Access for El Paso v. Hawkins succeeded in getting the Fifth Circuit to accept review and ultimately reverse.

Other Texas Courts

Merits Briefs.  This appellant's brief  in HCA Healthcare Corp. v. Texas Department of Insurance attacked a trial court judgment that had struck down Texas's workers compensation reforms aimed at clearing out the backlog of disputes between hospitals and insurers. (The court of appeals reversed and rendered.)