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Texas Supreme Court

Significant Decision on Exception to 'Eight Corners' Rule

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Texas Supreme Court

ICT Amici Curiae Brief

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Thompson Coe has a deep and experienced group of appellate attorneys known for clear and persuasive briefs and strong oral advocacy. Acting as key partners to trial counsel throughout the entire litigation cycle, our appellate attorneys bring a unique skill set of compelling writing talents and a global perspective to every matter. They have the ability to challenge or defend lower court decisions effectively and to provide forceful arguments and innovative resolutions to meet our client’s needs.

Our appeal attorneys have handled thousands of appeals nationwide in state and federal courts, including the Supreme Court, the Fifth, Eighth, Ninth, and Tenth Circuits, and Texas, California, Louisiana, and Minnesota courts.

Our team includes former briefing attorneys or law clerks for state and federal judges, and seven attorneys who are Board Certified in Civil Appellate Law by the Texas Board of Legal Specialization. Our experience and expertise have consistently produced results for our clients, as reflected by our recently reported appellate decisions.

Appellate Services

Our full service Appellate Section sets Thompson Coe apart from other litigation firms. From the start to finish of litigation, our appellate attorneys are there to help secure victory in the trial courts and to preserve it on appeal—or, when necessary, to overturn an adverse result on appeal. Our appellate litigation law firm services include:

  • Appeals Perfecting, briefing and arguing appeals in appellate courts
  • Mandamus Briefing and arguing original proceedings in appellate courts
  • Trial appellate counsel Attending trials to provide support for trial attorneys on legal issues, including evidentiary disputes, trial motions, jury charge, and error preservation
  • Pretrial motions Drafting and arguing outcome-determinative pretrial motions such as motions to dismiss (based on lack of personal jurisdiction, forum non conveniens, failure to state a claim), Daubert motions, and summary judgment motions
  • Jury Charges Preparing jury questions and instructions and preserving error at the jury charge conference at trial
  • Post-trial motions Drafting and arguing motions for new trial and other post-trial motions
  • Supersedeas Bonds Assisting clients in obtaining supersedeas bonds to prevent execution on an adverse judgment during appeal and defending challenges to bonds
  • Amicus Curiae Briefs Preparing amicus briefs for filing in appeals in which our clients or trade groups are not parties but are interested in the outcome


Wade C. Crosnoe Chair

Wade C. Crosnoe


Gino J. Rossini Vice Chair

Gino J. Rossini


Andrew L. Johnson Vice Chair

Andrew L. Johnson


Representative Experience

Secured mandamus relief from district court’s order refusing to dismiss group of product-liability cases based on forum non conveniens.

Ford Motor Co., 591 F.3d 406 (5th Cir. 2009)

Secured reversal of court of appeals’ judgment setting aside jury verdict on auto manufacturer's claim against plaintiffs for fraudulent inducement into a settlement.

Ford Motor Co. v. Castillo, 444 S.W.3d 616 (Tex. 2014)

Obtained reversal of an award of guardian ad litem fees when there was no apparent conflict of interest between the next friend and injured minor in product liability action.

Ford Motor Co. v. Stewart, Cox, & Hatcher, P.C., 390 S.W.3d 294 (Tex. 2013)

Obtained reversal of trial court’s award of guardian ad litem fees based on insufficiency of evidence that the guardian ad litem personally performed services or that the services were necessary to the limited task for which he was appointed.

Ford Motor Co. v. Garcia, 363 S.W.3d 573 (Tex. 2012)

Obtained reversal of award of guardian ad litem fees for work done outside the scope of the guardian’s appointment.

Ford Motor Co. v. Chacon, 370 S.W.3d 359 (Tex. 2012)

Obtained reversal of court of appeals’ opinion reversing summary judgment for general contractor based on lack of duty to rectify or warn of a dangerous condition allegedly created by contractor’s work.

Allen Keller Co. v. Foreman, 343 S.W.3d 420 (Tex. 2011)

Secured reversal of trial court’s order refusing to permit auto manufacturer discovery into alleged fraud by plaintiffs’ counsel and juror misconduct in connection with settlement.

Ford Motor Co. v. Castillo, 279 S.W.3d 656 (Tex. 2009)

Obtained writ of mandamus re-urging the plaintiff to produce all settlement agreements with other settling defendants in product-liability case .

GreCon, Inc., 542 S.W.3d 774 (Tex. App.—Houston [14th Dist.] 2018, orig. proceeding)

Successfully defended defense verdict and partial summary judgment on appeal where Plaintiff alleged there was error in the jury charge and in granting partial summary judgment on DTPA and breach of the duty of good faith and fair dealing claims.

Brannan v. Ford Motor Co., 2018 WL 1057434 (Tex. App.—Houston [14th Dist.] 2018, no pet.)

Successfully defended defense verdict on plaintiffs’ claims that the trial court erred in excluding numerous alleged “other similar incidents” from evidence.

Estate of Muniz v. Ford Motor Co., 2013 WL 2645284 (Tex. App.—San Antonio 2013, no pet.)

Successfully defended the trial court’s grant of a directed verdict on plaintiff’s claims in a personal injury action.

Brinker v. Evans, 370 S.W.3d 416 (Tex. App.—Amarillo 2012, pet. denied)

on the legal insufficiency of the plaintiff's expert testimony on safer alternative design.

Ford Motor Co. v. Wiles, 353 S.W.3d 198 (Tex. App.—Dallas 2011, pet. denied)

Successfully defended a take nothing judgment for defendants based on the harmless error of submitting a jury question regarding the alleged victim’s own negligence in a personal injury action.

Crowson v. Bowen, 320 S.W.3d 486 (Tex. App.—Fort Worth 2010, no pet.)

Secured reversal of trial court's judgment notwithstanding the verdict awarding plaintiff full amount of past medical care damages in personal injury action based on the legally insufficient evidence supporting the jury’s award.

Bullard v. Lynde, 292 S.W.3d 142 (Tex. App.—Dallas 2009, no pet.)

Secured reversal of onerous conditions of dismissal in forum non conveniens dismissal order.

Ford Motor Co. v. Villanueva, 302 S.W.3d 476 (Tex. App.—Eastland 2009, no pet.)

Successfully defended summary judgment for defendants based on the lack of a duty to control the conduct of third parties when the risk of harm is not foreseeable in a personal injury action.

Dyess v. Harris, 321 S.W.3d 9 (Tex. App.—Houston [1st Dist.] 2009, pet. denied)

Successfully defended a take nothing judgment in favor of an automobile manufacturer based on the plaintiff's failure to meet the burden of proof required to prove a design defect.

Hunter v. Ford Motor Co., Inc., 305 S.W. 3d 202 (Tex. App.—Waco 2009, no pet.)

Successfully defended order granting motion to apply the law of Mexico in product-liability case.

Torres v. Bridgestone/Firestone N. Am. Tire, LLC, 498 S.W.3d 565 (Tenn. Ct. App. 2016)

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