Miles-Edmond v. Skillman Prop. Inv. Dallas LLC addressed “Malooly” issues and the need for appellants to challenge all potential bases for a trial court’s summary judgment ruling.

A general issue that the trial court erred in granting the motion for summary judgment might be sufficient to allow argument on all possible grounds.  However, the appellant must then, in fact, substantively attack each basis upon which the summary judgment could have been granted.

Here,”[b]ecause the summary judgment could have been based on these no-evidence grounds, and because Miles-Edmond failed to challenge these grounds, we must affirm the trial court’s summary judgment.”  No. 05-23-00789-CV (mem. op.) (Feb. 24, 2025).