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Fox Rothschild LLP

Masterclass: North Carolina Supreme Court Explains Error Preservation in the Directed Verdict and JNOV Context.

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Parties must move for a directed verdict to preserve their right to request judgment notwithstanding the verdict (JNOV*) after an unfavorable verdict is returned. Friday’s batch of Supreme Court opinions includes a...more

Chartwell Law

Where Appeals Begin

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I remember listening to Justice Frank Cleckley of the West Virginia Supreme Court of Appeals, my professor for Evidence, open his first lecture with a discussion of Federal Rule of Evidence 103. As a young law student, I was...more

Ward and Smith, P.A.

The Importance of Oral Arguments in Appellate Courts: Insights for Trial and Appellate Practitioners

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Recent stats show an interesting trend in the U.S. Court of Appeals for the Fourth Circuit: oral arguments are held in just 13% of cases. This differs from other circuits like the D.C. Circuit, where almost 50% of cases get...more

Carlton Fields

Asking for Oral Argument in the U.S. Courts of Appeals

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In many federal courts of appeals, the statement on oral argument occupies a prime position in a brief. It is often the first substantive statement a judge reads. Yet so few advocates use this valuable “real estate” to...more

Ward and Smith, P.A.

Playing the Long Game: Preserving Issues for Appeal

Ward and Smith, P.A. on

Trials happen fast. Trial counsel are rightly preoccupied with preparing to give opening statements or closing arguments, preparing to examine or cross-examine witnesses, or simply keeping track of admitted exhibits....more

Pullman & Comley, LLC

How Do I Get More Time to File My Appeal?

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As an appellate lawyer with considerable experience in both state and federal appellate courts, I often receive calls from colleagues who are either in the midst of trying a case, or who have just received a decision or...more

Miller Canfield

Thinking Ahead: Why You Should Consider Including an Appellate Lawyer on Your Trial Team

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It may seem odd to have an appellate lawyer participate during a trial. But a new decision from the Michigan Court of Appeals shows that a second set of eyes, with a view toward appeal, can benefit both clients and lawyers at...more

Esquire Deposition Solutions, LLC

The Role of Depositions in Preserving Trial Errors for Review

Whether it’s during a deposition or during trial, the job of preserving errors for judicial review is a vital part of the litigator’s professional obligation to his or her client. Many trial outcomes turn on evidentiary...more

Holland & Hart - Your Trial Message

Voir Dire on Content, Not Effect: Lessons from the Tsarnaev Appeal

We tend to think of “bias” as it applies to juries, but courts can have their own deep-seated practices. For example, judges will often prefer voir dire questions that focus on the juror’s own assessment of the influence of a...more

Baker Donelson

Mass (Trial) Appeal: How Incorporating an Appellate Attorney Can Benefit a Trial Team

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The importance of watching for and properly preserving issues for appeal cannot be understated. This is especially true in high stakes cases involving significant exposure or those having significant precedential value where...more

Carlton Fields

Don't Estop Believin' - Courts May Save Your Judicial Estoppel Argument

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The equitable doctrine of judicial estoppel prevents a party from asserting a claim in a legal proceeding that is inconsistent with a claim taken by that party in a previous proceeding. Generally, the doctrine is raised by a...more

McManis Faulkner

The Appellate Oral Argument

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The Appellate Court: An exciting forum of oral advocacy; a check on the process and the decisions of our trial courts; a second chance for parties to make their case; and a place where novel and important legal principles...more

Carlton Fields

Preserving The Record For Appeal: A Trial Lawyer's Checklist

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This checklist is intended as an overview to help trial lawyers preserve the record for appeal. It is not exhaustive of all steps necessary to preserve error in every situation. Certain rules may vary by state/federal...more

Robins Kaplan LLP

New York Appellate Division Implements New Statewide Practice Rules

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In September, the Appellate Division of the Supreme Court of the State of New York implemented new statewide practices rules that apply in each of New York’s four judicial departments. ...more

Carlton Fields

The Keys To Preserving Error For Appeal

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During a judicial career that spanned more than 25 years, Carlton Fields Shareholder Peter Webster presided over numerous jury trials as a circuit judge and authored hundreds of appellate opinions following his appointment to...more

Pillsbury - Policyholder Pulse blog

Forging New Paths: Incorporating Appellate Strategies into Insurance Litigation

Claim analysis and pre-trial preparation can sometimes become so focused on determining what the law is that lawyers lose sight of our ability to change that law. In some cases, that means discovering and arguing new legal...more

Holland & Hart - Your Trial Message

Expect Jury Leaders to Act as Individuals, not Representatives

What do we expect of our leaders? If you think about it in a political context, and if you get past your initial cynical thoughts about self-interest and corruption, then perhaps what you hope for is that our leaders make...more

Carlton Fields

Right for the Wrong Reason - Reversal Requires More Than Just an Error

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Challenging an adverse judgment on appeal is an uphill battle from the start. A major part of winning an appeal requires demonstrating that an error occurred and confirming that the error was properly raised in the trial...more

Carlton Fields

The Air of Preservation Is Now Filled With “Specific” Arguments

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To win, trial lawyers must master the art of persuasion. But when they lose, they are tested by their mastery of the art of preservation. As standards of review in appellate courts have become increasingly demanding,...more

McNees Wallace & Nurick LLC

The Top Five Reasons to Have Separate Appellate Counsel

An appeal is neither a chance to retry a case nor a time to develop new legal theories. A successful appeal depends on careful planning and extensive knowledge of the appellate process, as well as a meritorious legal...more

Carlton Fields

The Key to Jury Instruction Preservation: Objecting with Precision and Completeness

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In Byrd v. Stubbs, 190 So. 3d 26 (Miss. Ct. App. 2016), the Mississippi Court of Appeals reminded us of the need to be diligent during a charge conference by raising specific objections to a proposed jury instruction, as...more

Carlton Fields

Quick Trial Checklist

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This chart provides a quick reference regarding motions and objections that may be made immediately prior to, during, and immediately after trial to preserve issues for appellate review. ...more

Proskauer - Minding Your Business

Running Into A Brick Wall Who Wears A Black Robe: Tips For Trying A Case Before A Hostile Judge

For trial lawyers, hostile adversaries are par for the course. But judges are supposed to be irreproachably impartial, right? That is, after all, the very cornerstone of our judicial system. So when you find yourself trying...more

Carlton Fields

Getting It Right The First Time: Presenting A Persuasive Argument Without Relying On The Court’s Familiarity With The Facts Or The...

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Even apart from the importance of assuring appellate review, properly preserving the record and carefully laying out one’s argument can have an immediate impact at the trial level. Very often, a litigator comes across a...more

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