25-07: Less Appellate Law, More College Football
A look back to the weeks of August 4 and 11, with help from the collegiate gridiron
Welcome back to 1910 & Beyond, your regular briefing on the evolving landscape of appellate law in Houston and beyond. Each post highlights notable developments from Houston’s two courts of appeals—the First and Fourteenth—as well as from other state and federal appellate courts across Texas and nationwide. From time to time, I’ll also share practical tips on oral and written advocacy. I hope you find these posts useful to your practice and your understanding of what’s happening in Texas appellate law.
For those who have already subscribed, thank you. And for those who haven’t yet, I hope you’ll consider joining us!
As subscribers know, I’ve asked for feedback on 1910 & Beyond—what you enjoy, and what you don’t. In that spirit, I’m especially pleased to share (with permission) a comment from Matthew Morrissey, an exceptional Chicago litigator and close friend from law school:
Since you asked, I wanted to provide some feedback on your Substack. Please provide more college football content and less appellate law content. Gracias!
Claro que sí, Matt. I’d enjoy nothing more than mixing “nerdy law talk” with a topic that actually entertains. So this week, while we cover the usual items, I’ll also share some chatter on the upcoming college-football season—beginning with a guest appearance from one of my favorite college-football-podcast hosts—all with several nods to my favorite teams, of course.
1910
Orders and Opinions
As always, we begin with our local courts here in Houston. Over the past two weeks, both the First Court and the Fourteenth Court issued a steady stream of orders and opinions. Below, I highlight one notable opinion from each court, followed by brief summaries of others worth noting.
Features
CenterPoint Energy Houston Electric, LLC v. Wilder, No. 01-22-00853-CV (Rivas-Molly, Guiney, Morgan, JJ.) (op.): A lineman employed by contractor L.E. Myers fell from a CenterPoint-owned concrete transmission pole after a step bolt pulled out, leaving him severely injured. A Harris County jury found CenterPoint negligent, assigned it 51% responsibility, and awarded over $15 million in damages.
In an opinion by Justice Guiney, the First Court reversed and rendered a take-nothing judgment in favor of CenterPoint.
The court first held that Chapter 95 applies. CenterPoint qualifies as a “property owner” under Chapter 95 because a public utility easement constitutes “real property.” The transmission pole—from which the lineman fell while modifying it—was an “improvement” within Chapter 95’s scope.
Once Chapter 95 applied, the lineman had to prove both that CenterPoint retained control over his work and that it had actual knowledge of the dangerous condition but failed to warn. Not only did the jury charge allow findings based on constructive knowledge (“knew or should have known”), the record also contained no conclusive evidence that CenterPoint actually knew of any defect in the step bolt.
N.B.: CenterPoint confirms that easement ownership qualifies for Chapter 95 protection. It also underscores Chapter 95’s rigor: When it applies, constructive knowledge of a dangerous condition won’t do—the statute requires proof of actual knowledge.
ISI Contracting, Inc. v. Metropolitan Transit Authority of Harris County, No. 14-24-00119-CV (Wilson, Hart, McLaughlin, JJ.) (op.): ISI Contracting sued Metro after years of delay and eventual termination of a sewer-installation contract. The trial court dismissed all claims on governmental-immunity grounds.
In an opinion by Justice Wilson, the Fourteenth Court affirmed in part and reversed and in part.
Waiver of Immunity under the Local Government Contract Claims Act: Even presuming (without deciding) that ISI was required to show “a substantial claim with some evidentiary support” to defeat a plea to the jurisdiction, it did so here. ISI sufficiently alleged breach-of-contract claims falling within the Act’s clear waiver of immunity, including claims for (1) unpaid retainage and termination-for-convenience payments, (2) compensation for additional work and change orders, and (3) equitable adjustments for differing site conditions and suspension/delay orders.
Delay Damages: ISI’s claim for delay damages also fell within the Act’s waiver. And it adequately pleaded exceptions to the contract’s no-damages-for-delay clause (e.g., unforeseen conditions, bad faith, unreasonable delay), bringing its claims within Section 271.153(a)(1)’s limited waiver for owner-caused delays. But claims for unabsorbed overhead and other consequential damages remain barred.
Briefing Waiver: ISI failed to adequately brief its challenge to the dismissal of its remaining claims.
N.B.: Beyond serving as a cautionary note on briefing waiver, ISI Contracting highlights both the reach and limits of the Local Government Contract Claims Act. Contractors can overcome immunity for direct damages and owner-caused delay costs—but only if carefully pled within the statute’s narrow scope. No-damages-for-delay clauses may not be ironclad if bad faith, changed conditions, or unreasonable suspensions are credibly alleged.
CFB Break: Conference Power Rankings
For our first gridiron break, I turned to one of my favorite college-football podcasts: Split Zone Duo. I’m thrilled that host Alex Kirshner shared his 2025 conference power rankings—debuting here for the first time:
SEC
Big Ten
Big 12
ACC
American
Sun Belt
Mountain West
MAC
Conference USA
Many thanks for contributing, Alex! Whether you’re a casual college-football fan or a diehard like me, Split Zone Duo is well worth the subscription.
In Brief
Now, let’s get to some “quick slants” from the First and Fourteenth Courts.
1COA
In re Quinn Emanuel Urquhart & Sullivan LLP, No. 01-25-00520-CV (Rivas-Molloy, Guiney, Morgan, JJ.) (order): Though perhaps not of jurisprudential significance, the First Court stayed a trial court’s order compelling the apex deposition of John Quinn—Quinn Emanuel’s Executive Chairman and Founding Partner—in a fee dispute. (To be a fly on the wall for that deposition.) The mandamus petition remains pending.
J. Davis Automotive Group Inc. v. Armitage, No. 01-23-00964-CV (Adams, C.J.; Caughey, Johnson, JJ.) (op.): The family of a Gulfgate employee who died from COVID-19 alleged that the dealership’s failure to implement protective measures caused her infection and death. The trial court denied the dealership’s motion to dismiss under the Pandemic Liability Protection Act, which requires an expert report with a factual and scientific basis linking the defendant’s failures to the plaintiff’s contraction of a pandemic disease. The First Court reversed. Although the report listed safety lapses and concluded that the employee “more likely than not” contracted COVID-19 at work, it did not explain how or why those lapses actually caused her infection—particularly given COVID-19’s widespread transmissibility. The Court rendered judgment dismissing the claims with prejudice and remanded for a determination of attorney’s fees and costs.1
In re NetJet Sales, Inc., No. 01-24-00325-CV (Rivas-Molloy, Guiney, Morgan, JJ.) (per curiam) (orig. proceeding): NetJets sought mandamus relief after the trial court denied its motion to dismiss Turner Construction’s claims under a forum-selection clause requiring litigation in Franklin County, Ohio. The First Court conditionally granted relief, rejecting all of Turner’s arguments:
The clause was mandatory and broadly covered all claims factually intertwined with the underlying agreement, as Turner’s claims here.
Turner’s arguments about lack of capacity went to the contract as a whole, not the clause itself, and thus did not defeat enforcement.
Turner’s alleged assignment of its interest did not affect the clause’s enforceability.
A non-signatory could enforce the clause as a “transaction participant” and under equitable-estoppel principles.
Turner failed to show overreaching or fraud, or that enforcement would be unreasonable or unjust.
Davidson v. City of Houston, No. 01-23-00914-CV (Rivas-Molloy, Guiney, Morgan, JJ.) (mem. op.): After the City placed a lien on his lot for emergency abatement of overgrown vegetation, Matthew Davidson sought declaratory relief, removal of the lien, and damages for an alleged unconstitutional taking. The trial court entered a take-nothing judgment in favor of the City. Affirming, the First Court held: (1) the trial court’s failure to issue findings of fact and conclusions of law was harmless when it did not prevent Davidson from properly presenting his arguments on appeal; (2) sufficient evidence—complaints of snakes and rats, debris posing fire and crime risks, and overgrowth along fences—supported an implied finding that the property created an “immediate danger” under Health & Safety Code § 342.008, validating the emergency abatement; and (3) no inverse-condemnation liability arose because the City abated a public nuisance, which is not a compensable taking.
14COA
Fuller v. McCulloch, No. 14-23-00436-CV (Jewell, Bridges, Antú, JJ.) (mem. op.): After two attorneys retained nearly $10 million under a contingency-fee agreement with a partially incapacitated client, the client’s guardians ad litem sought to prevent the attorneys from accessing those funds pending a fuller investigation, including an accounting. The trial court granted a temporary injunction and, after the attorneys repeatedly refused to comply with discovery and court orders, entered a default judgment against them. The First Court affirmed in full. Among other reasons:
The guardians had standing to pursue the funds’ recovery.
The attorneys’ challenges to the temporary injunction became moot after final judgment.
The trial court acted within its discretion in denying a continuance, particularly given evidence of delay tactics.
Default judgment was proper because the attorneys repeatedly refused to provide an accounting, respond to discovery, or pay sanctions—supporting the presumption their defenses lacked merit.
Okonrende v. Texas Children’s Hospital, No. 14-24-00001-CV (Wise, Jewell, Hart, JJ.) (mem. op.): After their five-week-old son died following medical complications, the Okonrendes sued several physicians, Baylor College of Medicine, and Texas Children’s Hospital for negligence and wrongful death. The trial court dismissed the Okonrendes’ claims, finding their expert report inadequate under Chapter 74 of the Texas Medical Liability Act. The Fourteenth Court reversed. The report—which was based on appropriate information—sufficiently described the standard of care (immediate oxygen for an infant in distress), the breaches by each physician, and how the delay caused the child’s death.
McCartney v. McCartney, No. 14-24-00310-CV (Christopher, C.J.; Jewell, McLaughlin, JJ.) (op.): In a divorce appeal, Ashley McCartney challenged (1) reimbursement awarded to the community estate for Thomas McCartney’s payments on her separate-property homes, (2) the reduction of her spousal maintenance below the amount agreed to in a marital-property agreement, and (3) the addition of new contingencies terminating maintenance. The Fourteenth Court largely affirmed, with modifications. Mostly rejecting Thomas’s challenge to the absence of a reporter’s record as unnecessary due to the pure issues of law, it upheld the reimbursement award—holding that the agreement did not waive reimbursement rights on behalf of the community marital state and that the trial court acted within its discretion in offsetting maintenance by reimbursement. But it struck conditions terminating maintenance on death, remarriage, or cohabitation, reasoning that Chapter 8 termination provisions do not apply to contract-based spousal-support agreements outside the Chapter 8 context.
Yu v. Hunan Hengzheng Science & Technology Co., No. 14-23-00808-CV (Christopher, C.J.; Jewell, McLaughlin, JJ.): After a failed investment and visa-related agreement, a Chinese citizen and his business (Hunan) sued franchisor Yu and his franchise (Frenchy’s) for fraud. The trial court granted summary judgment for Hunan after Yu and Frenchy’s failed to respond, as well as on Yu and Frenchy’s counterclaims. The Fourteenth Court affirmed in part and reversed in part. It reversed summary judgment for Hunan on its fraud claims, holding that—even without a summary-judgment response from Yu and Frenchy’s—the record contained no conclusive proof that they knowingly made false-refund promises, and that some evidence relied on was unauthenticated. But it affirmed the trial court’s refusal to withdraw their deemed admissions and the grant of summary judgment on their counterclaims.
Fournier v. Fernandez, No. 14-24-00009-CV (McLaughlin, Bridges, Boatman, JJ.) (mem. op. on reh’g): After a rear-end collision, a jury awarded two plaintiffs damages for pain and anguish, impairment, and medical expenses. On rehearing, the Fourteenth Court affirmed in part and reversed in part. It held that legally and factually sufficient evidence—including medical records and and expert medical testimony—supported causation findings. It also upheld the jury’s award for future physical impairment, based on evidence that disc bulges caused ongoing daily limitations. But it reversed the award for future medical expenses, finding that a chiropractor’s vague, generic note of possible future treatment was insufficient.
Arguments
Both the First and Fourteenth Court continue their summer oral-argument recess. Arguments resume on September 10 in the First Court and September 9 in the Fourteenth.
CFB Break: AP Preseason Top 25
Back to the gridiron. Here’s the Associated Press Preseason Top 25 Poll, with first-place votes in parentheses:
Texas (25)
Penn State (23)
Ohio State (11)
Clemson (4)
Georgia (1)
Notre Dame
Oregon (1)
Alabama
LSU
Miami
Arizona State
Illinois
South Carolina
Michigan
Florida
SMU
Kansas State
Oklahoma
Texas A&M
Indiana
Ole Miss
Iowa State
Texas Tech
Tennessee
Boise State
Louisville just missed the cut, landing at #29 with 90 votes.
& Beyond
Well into their summer recesses, things remain relatively quiet at the Supreme Courts of the United States and Texas.
SCOTUS
Unlike prior weeks, the U.S. Supreme Court’s emergency docket has been mostly still. Aside from denying a stay-of-execution application, the Court also denied an application to vacate the Fifth Circuit’s stay of the district court’s preliminary injunction in NetChoice v. Fitch, No. 25A97. That case involves NetChoice’s First Amendment challenge to Mississippi’s law requiring age verification and parental consent for minors using social-media websites. A district court enjoined the law’s application, but the Fifth Circuit (Southwick, Duncan, Englehardt, JJ.) summarily stayed that injunction pending appeal. NetChoice asked the Court to vacate that stay pending disposition of a cert. petition, which the Court summarily denied.
Justice Kavanaugh filed a short concurrence. While agreeing that the law likely violated the First Amendment, he concluded interim relief was inappropriate “because NetChoice has not sufficiently demonstrated that the balance of harms and equities favors its position at this time.”
The only other development at the High Court has been cosmetic: The Supreme Court’s docket page has gotten a facelift.
CFB Break: Heisman Favorites
Time for another college-football break. Even before kickoff, it’s already Heisman prediction season. Here are BetMGM’s current favorites—dominated, as usual, by quarterbacks:
Arch Manning (QB, Texas): +600
Garrett Nussmeier (QB, LSU): +900
Cade Klubnik (QB, Clemson): +900
Jeremiah Smith (WR, Ohio State): +1000
LaNorris Sellers (QB, South Carolina): +1600
Drew Allar (QB, Penn State): +1800
Julian Sayin (QB, Ohio State): +1800
DJ Lagway (QB, Florida): +1800
Gunner Stockton (QB, Georgia): +2000
Sam Leavitt (QB, Arizona State): +2000
Ty Simpson (QB, Alabama): +2000
SCOTX
Meanwhile, little to report from the Texas Supreme Court. The Court’s customary Friday orders lists consist of routine denials of petitions and motions, with one miscellaneous order granting a stay in an original proceeding challenging a discovery order that gave a third-party forensic examiner access to the Department of Family and Protective Services’ confidential-records system.
Other
Finally, let’s turn to two other appellate courts I closely follow: the U.S. Court of Appeals for the Fifth Circuit and the new Fifteenth Court of Appeals. (Call it overtime coverage.)
CA5
The Fifth Circuit continues to turn out notable opinions:
United States v. Paxton, No. 23-50885 (Higginbotham, Willett, Ho, JJ.): Voting-rights groups and the United States challenged Texas’s Election Protection and Integrity Act of 2021, which requires mail-in voters to provide ID numbers on applications and ballot envelopes. The district court enjoined the law under the Civil Rights Act’s materiality provision. The Fifth Circuit reversed and rendered judgment for Texas. After rejecting a jurisdictional challenge, the court held that the materiality provision applies only to voter-qualification paperwork, not mail-in balloting—and even if broader, the ID-number requirement is “material” because it confirms voter identity and legitimately advances Texas’s interest in preventing fraud.
Angelina Emergency Medicine Associates PA v. Blue Cross & Blue Shield of Alabama, No. 24-10306 (Smith, Higginson, Douglas, JJ.): Texas emergency-physician groups sued out-of-state Blue Cross plans (“Blue Plans”) for underpaying nearly 300,000 reimbursement claims based on patient assignments of benefits. The district court granted summary judgment for the Blue Plans on all bellwether claims, citing lack of standing and, alternatively, lack of administrative exhaustion. The Fifth Circuit affirmed in part and vacated in part. It affirmed dismissal of all claims with no written assignments. But it vacated as to the rest, holding that the district court erred by (1) treating ambiguous assignment language as unambiguous, (2) finding assignments of “all rights” insufficient to convey a right to sue regardless of administrative exhaustion, (3) applying the wrong estoppel standard to anti-assignment clauses, and (4) rejecting exhaustion despite evidence that providers followed the only appeals process known to them. The court remanded for additional factual development on the assignments’ validity and exceptions to exhaustion.
Romero-Lozano v. Bondi, No. 23-60638 (order by Willett, J.): This order illustrates the Fifth Circuit’s reluctance to recall the mandate. After his 2014 removal order was reinstated in 2022, Jose Ernesto Romero-Lozano petitioned for review of a subsequent BIA withholding-only decision. The parties jointly moved to remand the case so the BIA could reconsider certain evidence. The Fifth Circuit granted the motion, and the mandate issued in 2024. A year later, the Supreme Court decided Riley v. Bondi, 145 S. Ct. 2190 (2025), which held that BIA withholding-only orders are not “final orders of removal” triggering the 30-day review deadline. Citing Riley, Romero-Lozano moved to recall the mandate and reinstate his petition. Judge Willett denied the motion, holding that recalling a mandate is an extraordinary measure, that reinstatement would not cure the untimeliness of his original petition, and that any Riley issues could be raised in a new petition—and properly resolved by a merits panel—after the BIA rules on remand.
Nairne v. Landry, No. 24-30115 (Dennis & Ramirez, JJ.; Haynes, J., concurring in the judgment): After a seven-day bench trial, a single-judge federal district court enjoined Louisiana’s 2022 House and Senate maps for violating Section 2 of the Voting Rights Act by packing and cracking African-American voters. The Fifth Circuit affirmed.
Majority (Dennis & Ramirez, JJ.) (per curiam):
28 U.S.C. § 2284 does not require a three-judge panel for a purely statutory § 2 challenge.
Two organizations had organizational standing based on resource diversion—and even if they didn’t, individual voters had standing to pursue the claims.
The expedited trial schedule was within the district court’s “exceedingly wide” discretion.
On the merits, the plaintiffs met their burden under the Gingles factors to establish a § 2 violation.
Louisiana’s no-private-right-of-action argument was foreclosed by “settled and uniform precedent,” including from the Fifth Circuit.
Concurrence in the Judgment (Haynes, J.): No opinion. As Fifth Circuit practitioners know, Judge Haynes often forgoes writing separately when concurring only in the judgment.
Expect Louisiana to seek en banc review in Nairne—likely tied to Louisiana v. Callais, Nos. 24-109 & 24-110 (as discussed in last week’s post), where Section 2’s constitutionality is now squarely before the U.S. Supreme Court.
Texas v. Bondi, No. 24-10386: Texas challenged parts of the Consolidated Appropriations Act of 2023—including the Pregnant Workers Fairness Act and a $20 million appropriation—arguing that the House’s remote-voting procedures violated the Quorum Clause’s requirement of a majority “present.” The district court agreed and held that the Clause required physical presence, enjoining enforcement. A divided Fifth Circuit reversed.
Majority (Graves, J., joined by Higginson, J.): The enrolled-bill rule does not bar review because Texas’s challenge presents a pure question of law on undisputed facts. But that challenge fails on the merits: The Quorum Clause’s plain text and purpose, as well as historical practice, do not require physical presence.
Dissent (Wilson, J.): The majority is right on procedure but wrong on the merits. The Quorum Clause’s plain text, original understanding, and historical practice all support a physical-presence requirement.
Here as well, don’t be surprised to see Texas seek en banc review. Should the full Court take the case en banc and side with Judge Wilson, U.S. Supreme Court review would be all but certain: The Court unflinchingly takes cases invalidating major legislation.
Doe v. Jewell, No. 24-50480: This horrific case is the relatively rare example of a Title IX claim surviving dismissal. After a pre-K student was repeatedly molested by a substitute teacher, her parents brought a Section 1983 claim against the school and its principal. The principal moved to dismiss on qualified-immunity grounds, which the district court denied. The Fifth Circuit affirmed.
Majority (Higginbotham, J., joined by Willett, Ho, JJ.): Taking the allegations as true, the complaint states a violation of the child’s Fourteenth Amendment right to bodily integrity under circuit precedent: (1) the principal knew facts and a pattern pointing plainly to abuse (reports of lap-sitting, clothing sharing, locked doors, lying under a blanket); (2) she was deliberately indifferent (did not properly investigate, reprimand, or report the teacher; disregarded numerous reports of improper behavior; scolded reporting aides; and restructured classes in ways that increased isolation); and (3) that inaction plausibly caused the injury. The same conduct also “shocks the conscience”—though Judge Higginbotham alone “would not invoke the doctrine” because “it is a judicial creature responding to voids in the reach of § 1983[,]” which circuit precedent has filled. Regardless, because the right to bodily integrity was clearly established, qualified immunity was properly denied.
Concurrence (Ho, J.): The “shocks the conscience theory” has been criticized, but it remains binding precedent. And if economic harms can “shock the conscience” when reviewing excessive-damages awards, then so too can willful blindness to child sexual abuse.
CFB Break: Final SP+ Preseason Top 25
Now, to our final college-football break. If you’re obsessed with the sport like me, you’ve probably heard of Bill Connelly, creator of SP+ (formerly S&P+)—a ranking system designed to track overall team efficiency. As Bill explains:
SP+ is a tempo- and opponent-adjusted measure of college football efficiency. It is a predictive measure of the most sustainable and predictable aspects of football, not a résumé ranking, and, along those same lines, these projections aren't intended to be a guess at what the AP Top 25 will look like at the end of the year. These are simply early offseason power rankings based on the information we have been able to gather to date.’
Vegas keeps a close eye on Bill’s SP+ rankings, given its track record against the spread. Below is the final SP+ Preseason Top 25, with each team’s SP+ score in parentheses (points better than the average college-football team):
Ohio State (26.1)
Alabama (25.5)
Georgia (24.2)
Penn State (24.2)
Texas (23.1)
Notre Dame (22.0)
Oregon (22.0)
Michigan (20.9)
Ole Miss (20.7)
Clemson (20.2)
LSU (20.1)
Tennessee (19.4)
Texas A&M (18.3)
Miami (18.1)
Oklahoma (17.5)
Florida (16.2)
South Carolina (16.0)
Kansas State (15.3)
SMU (14.6)
Missouri (14.0)
USC (13.2)
Auburn (13.1)
Indiana (12.5)
Louisville (12.3)
Iowa (12.1)
15COA
Back to the courthouse. Two divided opinions from the Fifteenth Court—which celebrates its first birthday on September 1—caught my eye:
In re Office of Attorney General, No. 15-24-00091-CV (orig. proceeding): The Attorney General sought mandamus relief after a trial court denied its Rule 202 petition to depose Catholic Charities of the Rio Grande Valley in connection with a possible quo warranto action. A split court denied the petition.
Majority (Field, J., joined by Farris, JJ.): The Attorney General’s constitutional and statutory “visitorial” powers do not entitle it to take pre-suit depositions as a matter of law. The trial court otherwise acted within its discretion in denying the Rule 202 deposition given Catholic Charities’ cooperation with the investigation, the documents it already produced, and its sworn statement answering the Attorney General’s questions.
Dissent (Brister, C.J.): The majority correctly holds that the Attorney General cannot demand a presuit deposition as a matter of law. But it errs in rejecting mandamus relief under Rule 202, failing to account for both the “extraordinary” context of the border crisis and the inadequacy of the sparse records provided.
Oncor Electric Delivery Co. v. Public Utility Commission of Texas, No. 15-24-00042-CV (op.): The PUC issued a rate order regarding Oncor’s utility rates. Oncor moved for rehearing, leading to an amended order on rehearing that partially granted relief. Rather than file a second motion for rehearing, Oncor sought judicial review. The trial court dismissed for lack of subject-matter jurisdiction, reasoning that Oncor’s failure to file a second rehearing motion barred review. A divided court affirmed.
Majority (Field, J., joined by Christopher, C.J., sitting by designation): Under the Texas APA, a second rehearing motion is not required if the agency’s order makes solely “a typographical, grammatical, or other clerical change identified as such by the agency in the order.” Tex. Gov’t Code § 2001.146(h) (emphasis in opinion). But here, the PUC modified its order on a substantive matter raised in Oncor’s first rehearing motion. And it didn’t label its changes as only clerical, grammatical, or typographical. Oncor thus was required to file a second motion for rehearing as a prerequisite to judicial review.
Dissent (Farris, J.): Section 2001.146’s default rule is that a second rehearing motion is not required, and the majority’s reading lets the exception swallow the rule. What’s more, Oncor challenged only specific disallowances that the PUC’s amended order left unchanged; requiring a second rehearing motion on already-rejected issues would be a futile act.
Red Light
With that, the clock has hit triple zeros. Thanks for indulging my college-football digressions this week. As much as I would love to make pigskin talk a permanent feature, I’ll stick to what I know and leave the real analysis to the true experts—like the hosts of Split Zone Duo. And a special thanks again to Alex Kirshner for providing his preseason conference power rankings.
As this week’s theme shows, I welcome your feedback and suggestions for 1910 & Beyond. Please don’t hesitate to leave a comment or email me with thoughts, topic ideas, or tips on interesting cases.
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I’ll be back in a couple of weeks with another post—and some exciting professional news. Until then, enjoy Week 1 (and, even better, Week 0) of college-football kickoff!
Disclaimer: I represented the appellees in this case.