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Civil Procedure,
Appellate Practice

Aug. 10, 2026

Laying up or going for the green? Maniago and the risks of aggressive appellate strategy

Appellate strategy, like golf, rewards patience over shortcuts. In Maniago, the California Supreme Court reminds litigants that the quickest path to review may forfeit it altogether.

Andrew Workman

Associate
Reed Smith LLP

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Charles Hyun

Counsel
Reed Smith LLP

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Kasey Curtis

Partner
Reed Smith LLP

Email: kcurtis@reedsmith.com

Kasey practices in the firm's Appellate Group and is resident in the Los Angeles office.

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Laying up or going for the green? <i>Maniago</i> and the risks of aggressive appellate strategy
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Attorneys and golfers have more in common than you'd think. They navigate landscapes marked by strict rules, hazardous roughs and dramatic twists of fate. And they have all experienced the ruling (or shot) that leaves their case (or round) buried in a bunker. The demurrer gets sustained (shank!), the punitive damages claim gets struck (fore!), and suddenly your ball is stuck in a sand trap. Appellate review lies only 10 yards away, and one clean swing could mean the differenc...

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