Appellate Forfeiture as a Last Resort: Adequate Briefing Without Authority Citations in Borusan Mannesmann Pipe US, Inc. v. Hunting Energy Services, LLC

Appellate Forfeiture as a Last Resort: Adequate Briefing Without Authority Citations in Borusan Mannesmann Pipe US, Inc. v. Hunting Energy Services, LLC

I. Introduction

The Supreme Court of Texas’s per curiam opinion in Borusan Mannesmann Pipe US, Inc. v. Hunting Energy Services, LLC, No. 24‑0183 (Tex. June 27, 2025), is not about who ultimately must pay for defective oilfield pipe. Instead, it addresses a more systemic question: when does an appellant’s brief become so deficient that an appellate court may refuse to consider an issue at all?

The Court uses this commercial dispute as a vehicle to clarify two important procedural points:

  • Appellate forfeiture (often loosely called “waiver”) based on briefing defects should be a last resort, not a routine shortcut.
  • Texas Rule of Appellate Procedure 38.1(i) does not impose any minimum number of citations to case law or statutes. Adequate record citations accompanied by coherent legal arguments can be sufficient to preserve an issue for review, even if the brief cites no authorities.

The Court therefore reverses the Fourteenth Court of Appeals’ judgment, which had refused to reach the merits of Borusan’s indemnity argument on the ground that the argument was inadequately briefed, and remands for consideration of that issue on the merits.

II. Background of the Case

A. The Parties and the Commercial Setting

The dispute arises out of the oil and gas supply chain:

  • Borusan Mannesmann Pipe US, Inc. – a manufacturer of steel pipes.
  • Hunting Energy Services, LLC – a service provider that “swages” (expands) and “threads” pipes and supplies connectors.
  • Sooner Pipe LLC – a pipe distributor to whom Borusan sold threaded pipes.
  • Concho Resources, Inc. – the eventual end user that discovered defective pipes in its drilling operations.

The basic commercial flow was:

  1. Sooner ordered threaded pipe from Borusan.
  2. Borusan issued purchase orders to Hunting for connectors and threading work.
  3. Borusan delivered its pipes to Hunting; Hunting swaged and threaded them, then delivered them to Sooner.
  4. Borusan invoiced Sooner; Sooner later sold the pipe to Concho.

The defects manifested at the very end of this chain: Concho discovered holes in the pipe, was forced to abandon wells, and incurred substantial damages. Borusan and Hunting blamed each other for the defects.

B. The “Battle of the Forms” and Indemnity Terms

The case is structurally a classic “battle of the forms” problem: whose printed terms and conditions govern the contract relationship and, specifically, who promised to indemnify whom?

1. Borusan’s purchase orders to Hunting

Borusan’s purchase orders to Hunting:

  • Included Borusan’s standard terms and conditions; and
  • Contained a clause:
    “Any additional or differing terms or conditions contained in any documents issued by [Hunting] … shall not become a part of the Purchase Order and are hereby rejected by [Borusan] unless expressly agreed upon in writing by an authorized representative of [Borusan].”

Among Borusan’s terms was a provision requiring Hunting to indemnify Borusan for pipe defects.

2. Hunting’s invoices to Borusan

After delivering to Sooner, Hunting invoiced Borusan. Each invoice stated that:

“Hunting’s terms and conditions apply as stated at Hunting-Intl.com.”

Hunting’s online terms included a broad indemnity provision in all caps:

“BUYER SHALL BE LIABLE FOR, AND SHALL DEFEND, INDEMNIFY AND HOLD HARMLESS SELLER … FROM AND AGAINST ANY AND ALL CLAIMS WHICH ARISE OUT OF THE PERFORMANCE OF THE CONTRACT.”

Under that language, the “buyer” (here, Borusan) would indemnify the “seller” (Hunting).

3. Borusan’s invoices to Sooner

Borusan’s invoices to Sooner further complicated the picture. They provided that delivery was:

  • “[S]ubject to Borusan[]’s standard terms and conditions”; and
  • “[S]ubject also to Hunting[’s] general terms and conditions of sale,” which were attached.

Thus, Hunting’s terms (including its indemnity clause) were expressly incorporated into Borusan’s sales to Sooner.

C. The Litigation and Trial Court Rulings

After Concho discovered the defects and incurred major losses, conflict broke out upstream:

  • Hunting sued Borusan, alleging:
    • Breach of contract
    • Negligence
    • Fraud
    • Negligent misrepresentation
    • Breach of warranty
    • And seeking a declaratory judgment that Borusan must indemnify Hunting
  • Borusan counterclaimed for breach of contract and breach of warranty and sought a declaratory judgment that Hunting must indemnify Borusan.

The trial court:

  • Ruled for Hunting on all substantive issues.
  • Entered a partial judgment declaring that:
    • Hunting had no obligation to indemnify Borusan; and
    • Borusan was required to indemnify Hunting.

Critically, the court’s judgment:

  • “Found” that the purchase orders and invoices between Borusan and Hunting, and the corresponding documents between Borusan and Sooner, were:
    • “valid and enforceable contracts”; and
    • “the commercial documents that govern[ed] the relationship between the parties.”

Borusan requested findings of fact and conclusions of law under Texas Rules of Civil Procedure 296 and 297. The trial court issued:

  • Sixty‑five findings of fact and twenty‑four conclusions of law.
  • Those findings included that the invoices Hunting sent to Borusan and the purchase orders from Borusan to Sooner were “the commercial documents that govern[ed] the relationship between the parties.”
  • But the separate findings/conclusions did not repeat the judgment’s statement that the invoices were “valid and enforceable contracts.”

Six months later, the court entered a final judgment, repeating the partial judgment’s “valid and enforceable contracts” language and awarding attorney’s fees to Hunting.

D. The Appeal to the Fourteenth Court of Appeals

On appeal, a key issue was Borusan’s challenge to the declaratory judgment:

“[T]he trial court reversibly erred when it held that Borusan must indemnify Hunting.”

The court of appeals characterized the trial court’s “valid and enforceable contracts” determination as a “finding of fact,” and concluded that, to overturn that “finding,” Borusan needed to adequately brief why Hunting’s invoices were not valid and enforceable contracts.

The court of appeals held that Borusan had forfeited this argument via inadequate briefing because:

  • Borusan cited no authority (cases or statutes) to support its argument that it did not owe contractual indemnity to Hunting.
  • Borusan provided “no legal analysis” as to why the invoices were not valid and enforceable contracts.

Citing Texas Rule of Appellate Procedure 38.1(i), the court “decline[d] to perform the research and analysis” it believed Borusan had omitted and refused to address the indemnity issue on the merits.

Borusan filed a motion for rehearing, which was denied, and then petitioned the Supreme Court of Texas for review. The petition challenged only the court of appeals’ forfeiture holding; the underlying merits of indemnity are not yet before the Supreme Court.

III. Summary of the Supreme Court’s Opinion

The Supreme Court of Texas:

  • Reverses the Fourteenth Court of Appeals’ judgment.
  • Holds that Borusan’s briefing in the court of appeals was adequate to preserve its challenge to the trial court’s determination that Borusan must indemnify Hunting.
  • Emphasizes that:
    • Forfeiture based on briefing defects should be a last resort.
    • There is no inherent minimum requirement of case or statutory citations in an argument to avoid forfeiture; “appropriate” authority citations under Rule 38.1(i) do not always mean numerous or even any case citations.
  • Remands the case to the court of appeals to decide the indemnity issue on the merits, with discretion either to:
    • Order supplemental briefing under Rule 38.9(b), if needed to assist the court; or
    • Resolve the issue on the existing briefing.

The Court does not decide:

  • Which contractual terms ultimately govern the indemnity relationship between Borusan and Hunting.
  • Who, as between the parties, must indemnify whom.
  • How to resolve the underlying “battle of the forms” under substantive contract law.

The holding is deliberately narrow: the opinion is about issue preservation and briefing adequacy, not about the substance of indemnity or contract formation.

IV. Analysis

A. Precedents and Authorities Cited

1. Bertucci v. Watkins, 709 S.W.3d 534 (Tex. 2025)

Bertucci is the pivotal recent authority. The Court in Borusan explicitly builds on it in two main respects:

  1. Waiver vs. forfeiture terminology
    The opinion reiterates a clarification from Bertucci (which itself relies on the U.S. Supreme Court’s decision in United States v. Olano):
    • Forfeiture is the failure to timely assert a right.
    • Waiver is the intentional relinquishment or abandonment of a known right.
    Although litigants and courts often say “waiver” loosely, the Court stresses that what happened here is properly classified as “[alleged] forfeiture” due to briefing defects.
  2. Merits preference and use of Rule 38.9(b)
    Bertucci reaffirmed that:
    • Appellate courts should generally strive to decide cases on their merits rather than dismissing them on procedural technicalities.
    • Briefing may be adequate to preserve an issue but still be less than ideal in assisting the court. In such cases, Rule 38.9(b) allows the court to request supplemental briefing rather than defaulting to forfeiture.

    Borusan quotes and applies this framework, emphasizing that a “finding of insoluble forfeiture” should be a last resort.

2. Perry v. Cohen, 272 S.W.3d 585 (Tex. 2008)

The Court cites Perry v. Cohen for a broad, institutional principle:

“[A]ppellate courts should reach the merits of an appeal whenever reasonably possible.”

In Borusan, this maxim undergirds the Court’s disapproval of the court of appeals’ refusal to address the indemnity issue based solely on an asserted failure to cite supporting legal authority.

3. United States v. Olano, 507 U.S. 725 (1993)

Olano is a federal criminal procedure case, but it is imported here for its influential definitions of “waiver” and “forfeiture.” The Texas Supreme Court quotes Olano in Bertucci, and then again in Borusan, to:

  • Differentiate intentional abandonment (waiver) from mere failure to assert a right (forfeiture).
  • Ground its terminology in a well-established national framework.

4. Rules of Appellate and Civil Procedure

The opinion centrally interprets two appellate rules and one civil rule:

  • Texas Rule of Appellate Procedure 38.1(i) – requires briefs to contain:
    “a clear and concise argument for the contentions made, with appropriate citations to authorities and to the record.”
  • Texas Rule of Appellate Procedure 38.9(b) – authorizes courts to order supplemental briefing to “assist [the court] in performing its function” when briefing is defective but potentially curable.
  • Texas Rule of Civil Procedure 299a – provides that:
    • Findings of fact must not be recited in a judgment; and
    • If there is a conflict between findings of fact recited in a judgment (in violation of the rule) and separately issued findings under Rules 297 and 298, the “latter findings” control for appellate purposes.

5. Conflicting intermediate appellate cases on Rule 299a

The Court also notes but expressly declines to resolve a division among courts of appeals concerning how to treat improper findings of fact recited in a judgment:

  • R.S. v. B.J.J., 883 S.W.2d 711 (Tex. App.—Dallas 1994, no writ)
    • Treats such findings as invalid, leading appellate courts to affirm if the judgment can be supported on any basis in the record.
  • Hill v. Hill, 971 S.W.2d 153 (Tex. App.—Amarillo 1998, no pet.)
    • Gives findings in the judgment “probative value” so long as they do not conflict with separate findings.

The Supreme Court reserves that Rule 299a issue “for a future case that properly implicates it.”

B. The Court’s Legal Reasoning

1. Narrow framing of the issue

The Court carefully narrows the question before it:

  • Everyone assumes (for this appeal) that:
    • The trial court’s determination that the invoices were “valid and enforceable contracts” is treated as a finding of fact.
    • Borusan, as the appellant, bore the burden to adequately challenge that finding in the court of appeals.
  • Given those assumptions, the only question for the Supreme Court is:
    Did Borusan’s brief in the court of appeals adequately challenge the “finding” that Hunting’s invoices were valid and enforceable contracts, so as to avoid forfeiture?

By proceeding on the parties’ framing, the Court does not need to reach (and does not decide):

  • Whether the “valid and enforceable contracts” determination is genuinely a fact finding or a legal conclusion.
  • Whether Rule 299a was properly applied by the court of appeals.

2. Reaffirmation of a merits-first philosophy

Citing Bertucci and Perry, the Court reiterates that:

  • Appellate courts should, “whenever reasonably possible,” decide appeals on the merits.
  • Forfeiture or waiver based on briefing defects should be a “last resort.”

In this context, the Court disapproves of the court of appeals’ summary conclusion that Borusan’s argument was so inadequately briefed as to be forfeited entirely.

3. What Borusan actually did in its brief

The opinion makes an important factual point about the contents of Borusan’s appellate brief:

  • Borusan devoted “roughly five pages” to explaining why it did not agree to indemnify Hunting.
  • Its arguments included, among others:
    • That Borusan’s purchase orders expressly provided that:
      • Its terms were the only terms between the parties; and
      • Any additional/differing terms in Hunting’s documents were rejected unless expressly accepted in writing by an authorized Borusan representative.
    • That no evidence showed Borusan ever “expressly agreed” in writing to Hunting’s terms and conditions.
    • Therefore, the indemnity language in Hunting’s invoices never became part of the agreement.
  • Borusan also:
    • Cited the record extensively (documents, testimony, and the trial court’s findings and conclusions).
    • Critically engaged with the trial court’s reasoning about the governing “commercial documents.”

The Court characterizes these arguments as direct challenges to the “finding” that Hunting’s invoices were valid and enforceable contracts and concludes that they preserved Borusan’s key appellate issue.

4. Clarifying Rule 38.1(i): No “minimum citations” requirement

Rule 38.1(i) demands:

“A clear and concise argument for the contentions made, with appropriate citations to authorities and to the record.” (emphasis added)

The court of appeals relied heavily on the absence of supporting case or statutory citations for Borusan’s indemnity argument. In response, the Supreme Court makes three connected points:

  1. “Appropriate” authority citations are context-dependent
    Not every appellate issue will depend on statutes or prior case law in a way that requires extensive citation. Some issues (particularly those about the meaning of specific contract language or the existence of assent) can be argued largely through record-based reasoning.
  2. No numeric threshold
    The Court explicitly rejects any implicit rule that a party must cite some minimum number of cases or statutes (or any at all) to avoid a finding of forfeiture:
    “There is no inherent minimum quotient of statutory or case-law citations that must be met before a brief can be found to adequately preserve an issue.”
    A party is not required to “conjure up marginally related statutes or cases just to avoid a finding of forfeiture.”
  3. Record citations can be enough for preservation
    Where a party:
    • Clearly articulates its argument, and
    • Cites the relevant portions of the record,
    the issue is preserved—even if the argument might have been developed more fully with authority.

In short, Rule 38.1(i) is a tool to ensure that appellate courts can understand the parties’ arguments and find the supporting materials; it is not intended to be used as a trap to dispose of appeals without reaching their merits.

5. Preservation vs. persuasiveness and the role of Rule 38.9(b)

The Court carefully distinguishes:

  • Preserving an issue for review; from
  • Persuasively arguing that issue to an appellate court.

It acknowledges that:

  • Some briefing, while adequate to preserve error, may nevertheless fail to “properly assist an appellate court.”
  • In such cases, Rule 38.9(b) empowers (but does not obligate) an appellate court to order supplemental briefing.
  • If the court declines to do so, it may still decide the issue on the merits, and the weakness of the briefing may be reflected in the outcome (i.e., the court may simply reject a poorly developed argument).

The Court stresses that Rule 38.9 is:

“A tool to assist the court in performing its appellate function; it does not burden the court with an obligation to allow a party an additional bite at the briefing apple.”

Applied here, this means:

  • The court of appeals was not required to order supplemental briefing; but
  • It was error to treat Borusan’s argument as entirely forfeited, since the issue was adequately preserved on the existing brief.

6. The Court’s treatment of Rule 299a and the findings-in-judgment problem

A subsidiary procedural wrinkle concerns Rule 299a’s prohibition on reciting findings of fact in the judgment. The trial court’s:

  • Separate findings of fact and conclusions of law did not include a finding that the invoices were valid and enforceable contracts.
  • Partial and final judgments did recite such a “finding.”

The court of appeals treated the “finding” in the judgment as controlling because it came later in time than the separate findings, citing Rule 299a. The Supreme Court corrects the interpretation of the rule:

  • Rule 299a says that if there is a conflict between:
    • Findings of fact recited in the judgment (in violation of the rule); and
    • Findings of fact made under Rules 297 and 298 (i.e., in a separate document);
    then “the latter findings will control.”
  • The “latter” references the separately issued findings, not the findings made “later in time.”

However, the Court ultimately does not decide whether the court of appeals misapplied Rule 299a or whether the “valid and enforceable contracts” determination should instead be classified as a conclusion of law. It proceeds on the assumption (shared by the parties) that Borusan had to challenge the “finding” and focuses solely on whether its briefing did so adequately.

C. Impact on Texas Appellate Practice and Substantive Law

1. Strengthening the presumption of merits review

Borusan is part of a now-clear line of cases (Perry, Bertucci, and others) that:

  • Disfavor the use of procedural default (especially briefing defects) as a quick way to dispose of appeals; and
  • Encourage resolution of disputes on their substantive merits wherever reasonably possible.

For appellate practitioners and courts, this means:

  • Labeling an issue “waived” or “forfeited” based solely on briefing defects should be done cautiously.
  • Where a party has:
    • Clearly identified the issue; and
    • Articulated arguments with meaningful record citations;
    courts should generally treat the issue as preserved, even if the briefing could have been more robust.

2. Clarifying Rule 38.1(i) expectations

The decision concretely affects how lawyers should think about Rule 38.1(i):

  • There is no per se rule that an argument without case citations is automatically forfeited.
  • “Appropriate” authority citations are required, but:
    • If no statutes or cases directly govern the point, a party is not obliged to “pad” its brief with tangential authorities.
    • Strong record citations and coherent explanation of the legal position may suffice for preservation.
  • However, from a strategic standpoint, practitioners should still:
    • Strive to support arguments with applicable authority wherever reasonably available; and
    • Recognize that lacking authority can affect the persuasiveness (if not the preservation) of an issue.

In short, Borusan provides a safety net against harsh forfeiture based on imperfect briefing, but it does not dilute the expectation of professional, well-supported advocacy.

3. Promoting the use of supplemental briefing (without mandating it)

The opinion encourages courts to view Rule 38.9(b) as a pragmatic tool. For appellate panels facing underdeveloped but potentially important issues:

  • Ordering supplemental briefing is an available option where additional clarification would materially aid decision-making.
  • But Rule 38.9(b) does not impose an obligation; courts may decide issues based on existing briefing, recognizing that weak arguments will likely fail on the merits.

This reiteration may make appellate courts somewhat more inclined to use supplemental briefing in close cases, but the decision’s primary thrust is to limit forfeiture, not to expand briefing.

4. Substantive contract/indemnity implications (indirect)

On the substantive side, Borusan does not resolve the underlying indemnity dispute, but it:

  • Ensures that the Fourteenth Court of Appeals will now have to grapple with:
    • Which documents constitute the operative contract(s) between Borusan and Hunting; and
    • Whether and how the indemnity clauses in Borusan’s purchase orders and Hunting’s invoices can be reconciled.
  • Signals that the Supreme Court is attentive to:
    • Complex “battle of the forms” issues involving cross-referenced and conflicting terms up and down a supply chain; and
    • The allocation of indemnity risk in such layered commercial relationships.

Whatever the court of appeals decides on remand may itself become an important precedent in Texas commercial and indemnity law, particularly in industries that rely heavily on standardized terms and conditions.

5. The unresolved Rule 299a issue

The Court’s discussion of Rule 299a, though dicta, signals future developments:

  • It quietly corrects a misreading of “latter findings” as “later in time,” explaining that the rule refers to the separate findings issued under Rules 297 and 298.
  • It highlights a split in intermediate appellate authority about:
    • Whether findings improperly placed in a judgment should be ignored or given some evidentiary weight.
  • It expressly reserves the issue for a future case, inviting a clean vehicle to resolve the conflict.

Trial judges and practitioners should therefore:

  • Continue to avoid putting findings of fact in judgments, in compliance with Rule 299a.
  • Recognize that the Supreme Court may soon more definitively regulate the appellate treatment of such findings.

V. Key Concepts and Terminology Explained

A. Indemnity

An indemnity clause is a promise by one party (the indemnitor) to:

  • Protect another (the indemnitee) against specified claims, losses, or liabilities, and
  • Often to defend the indemnitee in lawsuits arising from those claims.

In this case:

  • Borusan’s purchase orders purported to make Hunting the indemnitor, shielding Borusan from losses arising from pipe defects.
  • Hunting’s invoices, referencing its online terms, purported to make Borusan the indemnitor, protecting Hunting from any claims arising out of “the performance of the contract.”

B. “Battle of the Forms”

A “battle of the forms” occurs when:

  • Parties exchange purchase orders, quotes, invoices, and acknowledgments, each with their own pre-printed terms;
  • The terms conflict (or at least differ in material ways); and
  • They proceed with performance anyway.

The legal questions then include:

  • What constitutes the “offer” and what constitutes the “acceptance”?
  • Which set of terms controls, especially where there are “knockout” clauses or rejection language?
  • Whether and how additional or different terms become part of the contract.

In Borusan, the core battle-of-the-forms issue is:

  • Whether Hunting’s indemnity clause (in its invoices and online terms) became part of its contract with Borusan despite:
    • Borusan’s explicit rejection language; and
    • The absence of evidence that Borusan expressly agreed in writing to those terms.

The Supreme Court does not resolve this issue; it only ensures that the court of appeals must now do so.

C. Waiver vs. Forfeiture

These two terms are often conflated but are distinct:

  • Forfeiture – A party fails to timely assert a right (e.g., does not raise an argument, or raises it in a procedurally improper way). The right is lost through inaction or insufficient action.
  • Waiver – A party intentionally relinquishes a known right (e.g., explicitly concedes an argument or strategy).

In appellate practice, “waiver” is frequently used loosely to include forfeiture, but the Supreme Court has increasingly insisted on the distinction in recent decisions like Bertucci and Borusan.

D. Findings of Fact vs. Conclusions of Law

After a bench trial, Texas courts may issue:

  • Findings of fact – determinations about “what happened” (e.g., “Hunting delivered pipes to Sooner on April 10, 2019”).
  • Conclusions of law – determinations about the legal effect of those facts (e.g., “The invoices constitute a binding contract,” “The indemnity provision is enforceable”).

Sometimes, trial courts label as “findings of fact” what are really legal conclusions, or vice versa. On appeal:

  • True findings of fact are reviewed for evidentiary sufficiency (legal or factual sufficiency standards).
  • Conclusions of law are reviewed de novo, i.e., without deference to the trial court.

In Borusan, the classification of the “valid and enforceable contracts” determination is left unresolved; the parties and the court of appeals treated it as a finding of fact, and the Supreme Court accepts that assumption solely for purposes of this procedural ruling.

E. Texas Rule of Appellate Procedure 38.1(i)

Rule 38.1(i) governs the argument section of an appellate brief. It requires:

  • A “clear and concise argument” for each contention; plus
  • “Appropriate citations”:
    • To legal authorities (cases, statutes, rules, etc.), and
    • To the record (transcripts, exhibits, findings, etc.).

If a party fails to comply, courts may:

  • Hold that a particular issue is inadequately briefed and therefore forfeited; or
  • Order supplemental briefing under Rule 38.9(b); or
  • Attempt to decide the issue on the merits if the arguments are sufficiently clear.

Borusan clarifies that Rule 38.1(i) does not require a mechanical minimum of citations; the focus is on whether the court can understand and fairly evaluate the argument.

VI. Conclusion: Significance of the Decision

Borusan Mannesmann Pipe US, Inc. v. Hunting Energy Services, LLC is a procedural decision with substantial practical impact. Its key contributions can be summarized as follows:

  • Forfeiture as a last resort. The Supreme Court reinforces a strong presumption in favor of deciding appeals on their merits, rather than disposing of them on technical briefing defects.
  • No minimum citation requirement. Texas Rule of Appellate Procedure 38.1(i) does not impose a numeric or formalistic requirement for case or statutory citations in every argument. Adequate preservation depends on clarity of argument and meaningful record citations, not on a citation “quota.”
  • Preservation vs. persuasiveness. The Court draws a clear distinction between briefing that is sufficient to preserve an issue and briefing that is sufficiently robust to win the issue. Weakly briefed but preserved arguments can be decided on the merits and rejected; they need not be declared forfeited.
  • Role of supplemental briefing. Rule 38.9(b) is highlighted as a discretionary tool for appellate courts to cure briefing defects when doing so will materially assist decision-making, without obligating courts to rescue inadequately represented parties.
  • Future clarification of Rule 299a. By flagging, but not resolving, the split in lower courts over findings placed in judgments contrary to Rule 299a, the Court signals that a future case may more definitively regulate that practice.

As for the parties themselves, the opinion returns the indemnity question to the court of appeals. Borusan and Hunting will now litigate, on the merits, whose forms and terms control and who must ultimately indemnify whom for the losses suffered by Concho. But beyond this particular dispute, Borusan will likely be cited frequently in Texas appellate courts as an authoritative reminder that:

Appellate briefing rules exist to facilitate reasoned adjudication, not to provide easy shortcuts around it.

Case Details

Year: 2025
Court: Supreme Court of Texas

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