On June 28, 2016, the U.S. District Court for the District of Delaware issued a long-awaited decision in Temple-Inland, Inc. v. Cook, No. 1:14-cv-00654. In a ruling on the parties’ cross motions for summary judgment, the district court granted Temple-Inland’s motion for summary judgment on its substantive due process claim and, in so doing, proclaimed Delaware’s historical method and practice of estimation unconstitutional.