What Remedy Should a Company Ask for on Appeal? Vacatur, Remand Instructions, Injunction Scope, and Severability in Florida, North Carolina, Federal Appeals, and U.S. Supreme Court Practice
Updated: Jul 24
Direct Answer
A company should not appeal only by arguing that the lower court was wrong. It should also tell the appellate court exactly what remedy it wants: reversal, vacatur, modification, remand with instructions, narrowed injunction, broader injunction, severability, new trial, entry of judgment, or further proceedings under a corrected legal standard.
Remedial strategy matters because winning the legal issue does not always produce the business result the client needs. The requested remedy can determine whether the case ends, returns to the trial court, preserves or dissolves an injunction, narrows a statute or contract, protects assets, or creates a path for further review.
The Answer Depends On Several Factors
The best appellate remedy depends on:
Whether the appeal is in Florida state court, North Carolina state court, federal court, the Eleventh Circuit, the Fourth Circuit, or the U.S. Supreme Court
Whether the order is final, nonfinal, interlocutory, injunctive, partial final, certified, or reviewable by extraordinary writ
Whether the appealing party seeks reversal, vacatur, modification, remand, new trial, entry of judgment, dismissal, narrowed relief, expanded relief, or reconsideration under the correct legal standard
Whether the lower court made a legal error, factual error, discretionary error, jurisdictional error, constitutional error, procedural error, or remedial error
Whether the record permits the appellate court to enter judgment or requires further fact-finding
Whether an injunction is overbroad, underinclusive, vague, unsupported, insufficiently specific, or directed at the wrong persons
Whether part of a statute, contract, regulation, order, injunction, or judgment can be severed from the invalid portion
Whether the appeal involves money, property, business operations, trade secrets, noncompetes, government action, constitutional rights, judgment enforcement, or emergency relief
Whether a stay, supersedeas, injunction pending appeal, temporary stay, or mandate stay is needed
Whether the remedy affects settlement leverage, attorney’s fees, costs, interest, injunction bond issues, or remand proceedings
Whether the remedy will preserve or destroy options for further review
Whether the case has Florida Supreme Court, North Carolina Supreme Court, Eleventh Circuit, Fourth Circuit, U.S. Supreme Court, or amicus significance
Why Remedial Strategy Matters on Appeal
Many appeals focus heavily on the error and too little on the remedy.
That is a mistake.
A company may win an appellate issue but still lose practical ground if the requested remedy is vague, incomplete, or poorly matched to the record.
For example:
A company may win reversal but still face years of remand litigation
A judgment may be vacated but the injunction may remain unclear
A statute may be invalidated more broadly than necessary
A contract clause may be struck when severability would preserve the business deal
A damages award may be reduced but attorney’s fees remain unresolved
A new trial may be granted when entry of judgment would have been available
A case may be remanded without instructions, leaving the trial court uncertain
An injunction may remain overbroad because the appeal attacked liability but not scope
Appellate counsel should ask at the beginning: “If we win, what exactly should the appellate court do?”
Reversal Versus Vacatur Versus Modification
These terms are often used together, but they are not identical.
Reversal
Reversal means the appellate court determines the lower court’s judgment or order was wrong.
Vacatur
Vacatur wipes out or nullifies the judgment, order, or portion of the order being vacated. Vacatur can matter when a party wants to prevent collateral consequences, preclusion, enforcement, or precedential effects from an order that should not remain in place.
Modification
Modification changes the judgment or order without necessarily requiring a full reversal. This may be appropriate when only the amount, scope, term, party, injunction language, or remedial condition needs adjustment.
Remand
Remand sends the case back to the lower tribunal for further proceedings. The key question is whether the remand should be broad or narrowly instructed.
A good appellate brief should use these terms deliberately.
Vacatur Strategy
Vacatur may be appropriate when the lower court’s order should not remain legally operative.
A party may seek vacatur of:
Final judgment
Injunction
Declaratory judgment
Sanctions order
Fee order
Damages award
Liability ruling
Jurisdictional order
Class-certification order
Administrative order
Bankruptcy order
Trial court findings
Appellate opinion in mootness situations
Portions of an order that create collateral consequences
Vacatur can be especially important when the order creates business harm, reputational harm, preclusion risk, injunction obligations, regulatory consequences, or future litigation risk.
Vacatur and Mootness
Vacatur can also arise when a case becomes moot while appellate review is pending.
If mootness occurs through happenstance or circumstances outside the losing party’s control, vacatur may be available to prevent an unreviewed judgment from producing unfair consequences.
If mootness results from settlement or voluntary action by the party seeking vacatur, vacatur is more difficult and depends on equitable considerations.
In business cases, mootness may arise from:
Sale of disputed property
Expiration of contract term
Completion of transaction
Withdrawal of challenged policy
Change in statute or regulation
Settlement
Bankruptcy
Dissolution of entity
End of injunction period
Completion of government action
Event that makes relief impossible
Vacatur should be requested promptly and supported by a clear equitable explanation.
Remand Instructions
A remand without instructions can create uncertainty.
A remand with instructions can tell the trial court exactly what to do next.
Possible remand instructions include:
Enter judgment for appellant
Enter judgment for appellee
Dismiss the claim
Conduct a new trial
Conduct a new damages hearing
Recalculate damages under a stated formula
Reconsider the injunction under the correct legal standard
Narrow the injunction to specific conduct
Dissolve the injunction
Apply a specific burden of proof
Make specific findings
Reconsider attorney’s fees
Conduct further proceedings consistent with the appellate opinion
Consider severability before invalidating an entire statute, contract, or order
Reconsider jurisdiction or standing
Apply a newly announced rule
Address unresolved defenses
Determine whether remaining claims survive after reversal
The more precise the requested remand, the less room there is for confusion after mandate.
Broad Remand Versus Limited Remand
A broad remand gives the trial court substantial flexibility.
A limited remand restricts what the lower court may do.
Broad Remand May Be Appropriate When:
Further fact-finding is required
The trial court must exercise discretion under a corrected legal standard
Multiple unresolved issues remain
The record is incomplete
The appellate court should not decide the issue first
The remedy depends on factual findings
Limited Remand May Be Appropriate When:
The record permits only one outcome
The legal error is dispositive
The trial court has no remaining discretion
A specific calculation is required
The injunction must be dissolved or narrowed
A claim must be dismissed
Judgment should be entered
The lower court already made all necessary findings
The brief should explain why the requested type of remand fits the record.
Injunction Scope on Appeal
Injunction appeals often turn not only on whether an injunction should exist but also on how broad it should be.
Appellate counsel should evaluate:
Who is bound
What conduct is restrained or required
Whether the injunction is specific enough
Whether the injunction reaches nonparties improperly
Whether the injunction is broader than the proven harm
Whether the injunction is geographically overbroad
Whether the injunction lasts too long
Whether the injunction burdens lawful conduct
Whether the injunction protects trade secrets, contracts, assets, customers, property, or constitutional rights
Whether the injunction contains adequate findings
Whether a bond is required
Whether a stay pending appeal is needed
Whether modification, not total reversal, is the right remedy
A company appealing an injunction should usually brief both entitlement and scope.
Overbroad Injunctions
An injunction may be overbroad if it restrains more conduct than necessary to remedy the proven violation.
Examples include:
Restricting lawful business activity beyond the dispute
Binding nonparties without a valid basis
Prohibiting speech or competition more broadly than necessary
Covering territories, customers, documents, or technology not tied to the record
Requiring affirmative acts not supported by findings
Freezing assets without an adequate basis
Reaching conduct outside the court’s jurisdiction
Extending beyond the duration necessary to protect the right
Failing to distinguish confidential information from public information
Prohibiting activity that was not adjudicated
The appellate remedy may be vacatur, reversal, narrowing, remand for modification, or dissolution.
Vague Injunctions
An injunction may be vulnerable if it does not clearly tell the parties what they must do or not do.
Vagueness matters because an injunction can lead to contempt. A company should not be forced to guess what conduct is prohibited.
A vague injunction may require:
Clarification
Modification
Vacatur
Narrowing
Remand for specific terms
Stay pending appeal
Emergency relief if contempt is threatened
In appellate briefing, counsel should identify the exact language that is vague and propose a workable alternative.
Injunctions and Stays Pending Appeal
Appealing an injunction does not always suspend it.
A company may need:
Stay pending appeal
Temporary stay
Supersedeas
Injunction pending appeal
Motion to suspend, modify, restore, or grant injunction relief
Emergency appellate relief
Stay of mandate
Supreme Court stay application in rare cases
Stay strategy should be coordinated with merits briefing. If the injunction will cause immediate business harm, waiting for final appellate decision may not be enough.
Severability Strategy
Severability asks whether an invalid portion of a statute, contract, regulation, injunction, or order can be separated from the valid parts.
Severability matters because appellate courts often prefer not to invalidate more than necessary.
In business and civil appeals, severability may arise with:
Contract clauses
Noncompete provisions
Arbitration agreements
Forum-selection clauses
Indemnity provisions
Fee provisions
Statutes
Regulations
Ordinances
Injunction provisions
Settlement agreements
Operating agreements
Purchase agreements
Licensing requirements
Corporate governance provisions
Administrative rules
A party should not assume that if one part is invalid, the whole instrument falls. Nor should a party assume severability is automatic.
Severability in Contract Appeals
In contract disputes, severability may determine whether a business deal survives.
Questions include:
Does the contract contain a severability clause?
Is the invalid term central to the bargain?
Can the remaining agreement function without the invalid term?
Would severance rewrite the parties’ bargain?
Does the governing state law allow blue-penciling or reformation?
Does the invalid term affect consideration, scope, remedy, or enforcement?
Does the contract involve arbitration, noncompete, confidentiality, sale terms, or indemnity?
Does severability affect attorney’s fees, forum, or damages?
The appellate remedy may ask the court to enforce the valid remainder rather than invalidate the entire agreement.
Severability in Constitutional and Statutory Appeals
In constitutional or statutory challenges, severability can determine whether the court invalidates:
A single clause
A statutory exception
A remedial provision
An enforcement mechanism
A subsection
An entire statute
A regulation
A licensing regime
A government policy
An ordinance
A narrower remedy may be more persuasive because courts often try to avoid unnecessary constitutional rulings and unnecessary disruption.
A party challenging a statute should explain whether the invalid portion can be severed. A party defending a statute should often argue for severability as a fallback.
Severability and Injunction Scope
Severability also applies to injunctions.
An appellate court may preserve valid portions of an injunction while vacating or narrowing invalid provisions.
For example:
Trade-secret restrictions may remain while noncompete restrictions are narrowed
Asset restraints may remain while unrelated business restrictions are removed
Confidentiality provisions may remain while speech restrictions are narrowed
Property-related restrictions may remain while nonparty restrictions are removed
Customer-solicitation restrictions may remain while employee restrictions are modified
A party should identify which parts of the injunction are independently supportable and which are not.
Remedy Preservation
A party must preserve remedial arguments.
Appellate counsel should ask:
Did the party request the desired remedy below?
Did the party object to the scope of the injunction?
Did the party propose narrower language?
Did the party argue severability?
Did the party ask for findings?
Did the party object to remand scope?
Did the party request entry of judgment rather than new trial?
Did the party ask for vacatur?
Did the party preserve constitutional avoidance or severability?
Did the party preserve stay or bond objections?
Appellate courts may be reluctant to grant a remedy that was not requested or developed below.
Remedy Framing in the Brief
The remedy should not appear only in the conclusion.
A strong appellate brief explains remedy throughout:
Issue statements should match the requested relief
Standard of review should support the remedy
Summary of argument should preview the remedy
Argument headings should identify the legal error and remedy
Record discussion should show why the remedy follows
Conclusion should request precise relief
Proposed remand language should be included when helpful
Alternative remedies should be presented in order of preference
The court should know exactly what the appellant wants before reaching the final page.
Alternative Remedies
A party may need to request alternative remedies.
For example:
Reverse and render judgment
Alternatively, vacate and remand for new trial
Alternatively, remand for further findings
Alternatively, narrow the injunction
Alternatively, sever the invalid provision
Alternatively, remand for reconsideration under the correct legal standard
Alternatively, vacate only the fee award
Alternatively, remand for recalculation
Alternative remedies should be logically ordered. They should not make the brief look uncertain, but they can preserve fallback relief.
Appellee Remedial Strategy
Remedial strategy is not only for appellants.
An appellee should also argue remedy.
An appellee may ask the court to:
Affirm outright
Affirm on alternative grounds
Affirm but modify the judgment
Affirm in part and remand only for limited proceedings
Preserve portions of an injunction
Apply severability to avoid broader reversal
Treat any error as harmless
Avoid vacatur because equitable factors do not support it
Limit remand instructions
Preserve fees, costs, interest, or bond rights
Clarify that enforcement remains available
An appellee should not assume that winning on liability automatically protects the remedy.
Florida Appeals: Remedial Strategy
In Florida civil appeals, remedial strategy may involve:
Reversal
Quashing an order in original proceedings
Vacatur
Remand for further proceedings
Remand with instructions
Modification of judgment
New trial
Narrowing or dissolving injunctions
Stay pending review
Mandate strategy
Written-opinion or certification strategy
Florida Supreme Court review
U.S. Supreme Court review if federal issues are preserved
Florida appellate strategy should also consider whether the requested remedy affects attorney’s fees, taxable costs, judgment enforcement, injunction compliance, supersedeas, and remand jurisdiction.
North Carolina Appeals: Remedial Strategy
In North Carolina civil appeals, remedial strategy may involve:
Affirmance
Reversal
Vacatur
Remand
Remand with instructions
New trial
Modified judgment
Supersedeas
Temporary stay
Mandate consequences
Petition for discretionary review
En banc rehearing
U.S. Supreme Court review if federal issues are preserved
North Carolina appellate strategy should consider whether the appellate court can decide the issue on the record or whether the case must return to the trial court for findings, discretion, or new proceedings.
Federal Appeals: Remedial Strategy
In federal appeals, remedial strategy often turns on 28 U.S.C. § 2106.
Federal appellate courts have authority to affirm, modify, vacate, set aside, reverse, remand, direct entry of appropriate judgment, or require further proceedings as may be just under the circumstances.
That broad remedial authority makes remedy framing especially important.
Federal appellate counsel should evaluate:
Whether the record supports entry of judgment
Whether further fact-finding is required
Whether vacatur is needed
Whether remand should be limited
Whether injunction scope violates Rule 65
Whether a stay or injunction pending appeal is needed
Whether severability can preserve valid portions of a statute, contract, or order
Whether Supreme Court review may later require a clean remedial record
U.S. Supreme Court Remedial Strategy
At the U.S. Supreme Court, remedy is often central.
A petitioner may seek:
Reverse
Vacate and remand
GVR
Summary reversal
Remand for application of a new standard
Narrower injunction
Severability
Munsingwear vacatur
Entry of judgment
Reconsideration in light of intervening authority
A respondent may seek:
Affirmance
Alternative grounds for affirmance
Narrower remedy
Severability
Harmless-error affirmance
Remand rather than reversal
Denial of vacatur
Preservation of injunction or judgment portions
Supreme Court strategy should include what the party wants the lower court to do after the decision.
Evidence and Record Checklist
A party developing remedial strategy should gather:
Judgment or order under review
Injunction text
Trial court findings
Record supporting or undermining each remedy
Proposed injunction language
Proposed narrower injunction language
Contract severability clause
Statutory severability clause
Legislative history if relevant
Contract drafting history if relevant
Motions and objections preserving remedy
Proposed orders submitted below
Hearing transcripts
Trial transcripts
Damages calculation
Fee and cost orders
Bond or security orders
Stay motions
Enforcement records
Evidence of business harm
Evidence of irreparable injury
Evidence of nonparty effects
Proposed remand instructions
Alternative remedy chart
Remedial briefing should be built from the record, not improvised at the end.
Deadline and Timing Issues
Important timing issues may include:
Notice of appeal deadline
Cross-appeal deadline
Stay deadline
Supersedeas deadline
Injunction compliance deadline
Motion to modify injunction deadline
Motion to dissolve injunction deadline
Rehearing deadline
En banc deadline
Mandate date
Motion to stay mandate deadline
Fee and cost deadlines
Bond objection deadline
Remand scheduling deadline
Deadline for petition for discretionary review
Deadline for Florida Supreme Court review
Deadline for U.S. Supreme Court certiorari
Deadline to seek Munsingwear vacatur if mootness develops
Deadline to notify the appellate court of intervening developments
Remedy can be lost by delay.
Common Mistakes by Appellants
Appellants should avoid:
Asking only for “reversal” without explaining what comes next
Ignoring vacatur when collateral consequences matter
Failing to request entry of judgment when the record supports it
Failing to request remand instructions
Ignoring injunction scope
Attacking an injunction generally without proposing narrower language
Forgetting severability
Failing to preserve remedy below
Ignoring stay needs
Ignoring mandate timing
Failing to address fees, costs, interest, and bond consequences
Raising too many remedies without priority
Waiting until oral argument to clarify the remedy
A strong appeal should give the court a practical path to relief.
Common Mistakes by Appellees
Appellees should avoid:
Defending the judgment but ignoring the remedy
Failing to argue harmless error
Failing to propose limited remand
Failing to defend severability
Ignoring overbreadth challenges to injunctions
Failing to preserve alternative grounds
Failing to protect fees, costs, interest, and bond rights
Failing to oppose vacatur when equitable factors matter
Assuming affirmance is the only possible outcome
Ignoring what happens after mandate
An appellee should tell the court what remedy is appropriate even if the court disagrees with the appellee on the main issue.
Risks Companies Should Not Ignore
Remedial strategy affects business risk.
Potential risks include:
Judgment remains enforceable
Injunction remains too broad
Injunction is vacated entirely
Remand is too open-ended
Trial court misreads mandate
Contract is invalidated more broadly than necessary
Statute or regulation is invalidated unnecessarily
Fees and costs survive reversal
Interest continues to accrue
Bond exposure remains
Settlement leverage changes
Remand litigation becomes more expensive than expected
Collateral consequences remain after legal victory
Further review becomes harder because remedy was unclear
Amicus or Supreme Court strategy is weakened
A company should evaluate appellate remedy as carefully as appellate liability.
Appeal Consequences
A remedial appellate decision may lead to:
Affirmance
Reversal
Partial reversal
Vacatur
Modified judgment
Limited remand
Broad remand
New trial
Entry of judgment
Recalculation of damages
Dissolution of injunction
Narrowing of injunction
Expansion of injunction
Severance of invalid provision
Preservation of valid provisions
Remand for findings
Remand for application of correct legal standard
Fee and cost proceedings
Stay or bond proceedings
Further appellate review
Supreme Court review
Settlement after remand
The remedy determines what happens next.
Practical Questions Before Filing an Appeal
Before filing an appeal, ask:
What exact remedy do we want?
Is the remedy supported by the record?
Did we ask for this remedy below?
Do we need reversal, vacatur, modification, or remand?
Should the remand be broad or limited?
Should the appellate court direct entry of judgment?
Is an injunction involved?
Is the injunction overbroad, vague, or insufficiently supported?
Can the invalid part be severed?
Is severability governed by a statute, contract, or common law?
Do we need a stay pending appeal?
What happens if mandate issues?
How will fees, costs, interest, or bond issues be affected?
What happens if we win only part of the appeal?
What happens on remand?
Does the remedy preserve further review?
These questions should shape the brief before drafting begins.
Practical Questions Before Oral Argument
Before oral argument, appellate counsel should be ready to answer:
What should the court do if it agrees with you?
Should the court reverse or vacate?
Should the court remand?
What should the remand instructions say?
Can the court enter judgment now?
What factual issues remain?
Should the injunction be dissolved or narrowed?
What specific injunction language is improper?
Can the invalid provision be severed?
What happens to fees and costs?
What happens to the stay or bond?
What happens if the court agrees only in part?
The remedy question should never surprise appellate counsel.
Authority Block
Authorities that may affect remedial strategy on appeal include:
28 U.S.C. § 2106, governing federal appellate authority to affirm, modify, vacate, set aside, reverse, remand, direct entry of judgment, or require further proceedings as may be just
Federal Rule of Appellate Procedure 8, governing stays and injunctions pending appeal
Federal Rule of Appellate Procedure 41, governing mandates in federal appeals
Federal Rule of Civil Procedure 65, governing injunctions and restraining orders, including specificity and persons bound
Federal Rule of Civil Procedure 52, governing findings and conclusions in bench trials and certain injunction contexts
Florida Rule of Appellate Procedure 9.310, governing stays pending review
Florida Rule of Appellate Procedure 9.330, governing rehearing, clarification, certification, and written-opinion motions
Florida Rule of Appellate Procedure 9.340, governing mandates
Florida Rule of Civil Procedure 1.610, governing injunctions
North Carolina Rule of Appellate Procedure 23, governing supersedeas and temporary stays
North Carolina Rule of Appellate Procedure 31, governing rehearing
North Carolina Rule of Appellate Procedure 32, governing mandates
North Carolina Rule of Civil Procedure 65, governing injunctions and restraining orders
Supreme Court severability decisions addressing whether invalid provisions should be severed or whether broader invalidation is necessary
Supreme Court vacatur decisions addressing mootness, settlement, and equitable vacatur
Eleventh Circuit, Fourth Circuit, Florida appellate, and North Carolina appellate authority governing vacatur, remand instructions, injunction scope, severability, stays, mandates, and harmless error
This list is not exhaustive. Remedial strategy depends on the forum, order, record, preserved issues, requested relief, business consequences, and further-review posture.
How Biazzo Law Approaches Remedial Strategy on Appeal
Biazzo Law represents businesses, professionals, individuals, organizations, in-house counsel, trial counsel, appellate counsel, and referring attorneys in Florida appeals, North Carolina appeals, federal appeals, emergency injunctions, civil litigation, business litigation, petitions for discretionary review, U.S. Supreme Court strategy, petitions for writ of certiorari, and amicus curiae matters.
Biazzo Law’s approach is appellate-aware and remedy-focused. An appeal is not treated as an abstract dispute over legal error. It is evaluated for what relief the appellate court can actually grant, what happens on remand, how injunctions should be shaped, whether invalid portions can be severed, whether vacatur is needed, whether a stay is required, and whether the remedy preserves further review.
Biazzo Law can help evaluate:
Whether to seek reversal, vacatur, modification, or remand
Whether remand should include specific instructions
Whether an injunction should be dissolved, narrowed, modified, or preserved
Whether severability should limit the remedy
Whether a stay, supersedeas, temporary stay, or emergency appellate motion is needed
Whether fees, costs, interest, or bond issues remain after appeal
Whether remedial strategy affects settlement, remand, or enforcement
Whether the case has Florida Supreme Court, North Carolina Supreme Court, Eleventh Circuit, Fourth Circuit, U.S. Supreme Court, or amicus significance
The goal is not simply to win an appellate issue. The goal is to obtain a remedy that actually protects the client’s legal, business, and strategic interests.
Related Biazzo Law Resources
Frequently Asked Questions
What is remedial strategy on appeal?
Remedial strategy is the plan for what the appellate court should do if it agrees there was error. It includes whether to seek reversal, vacatur, modification, remand, new trial, entry of judgment, narrowed injunction, severability, or other relief.
What is the difference between reversal and vacatur?
Reversal means the appellate court decides the lower court was wrong. Vacatur nullifies or wipes out the judgment, order, or portion of the order being vacated.
Why do remand instructions matter?
Remand instructions tell the lower court what to do next. Specific instructions can prevent confusion, limit unnecessary litigation, and protect the client’s win after appeal.
Can an appellate court narrow an injunction?
Yes. Depending on the record and governing law, an appellate court may affirm, reverse, vacate, modify, narrow, dissolve, or remand an injunction for further proceedings.
What is severability on appeal?
Severability asks whether an invalid part of a statute, contract, order, injunction, or regulation can be separated from the valid parts so that the entire instrument does not fall.
Should a party ask for alternative remedies?
Often, yes. A party may ask first for entry of judgment, then alternatively for vacatur, remand, new trial, narrowed injunction, or further proceedings under the correct standard.
Does an appeal automatically stop an injunction or judgment?
Usually no. A party may need a stay, supersedeas, temporary stay, injunction pending appeal, mandate stay, or emergency appellate relief.
Can Biazzo Law help with appellate remedy strategy?
Yes. Biazzo Law can help businesses, trial counsel, appellate counsel, organizations, and individuals evaluate vacatur, remand instructions, injunction scope, severability, stays, mandates, settlement posture, and further-review strategy in Florida, North Carolina, federal appeals, and U.S. Supreme Court practice.
Schedule a Litigation Strategy Review
Winning the legal issue is only part of the appeal. The remedy determines what happens next.
If your case involves an appeal from a judgment, injunction, constitutional ruling, business order, contract ruling, statutory challenge, remand, or emergency order in Florida, North Carolina, federal court, the Eleventh Circuit, the Fourth Circuit, or the U.S. Supreme Court pipeline, Biazzo Law can help evaluate the remedy, risks, deadlines, and next appellate step.
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