Grisaffi v. Rocky Mountain High presents an unusual situation involving the “one-satisfaction rule” (and the choice it requires between recovery of stock and damages for the loss of the same stock), the “mandate rule” requiring an election pursuant to that rule, and the effect of another proceeding arguably implicating the subject matter of this case. The majority affirmed, finding a faithful application of the mandate rule; a dissent had a different view about the import of the other action. No. 05-20-00538-CV (Oct. 18, 2022) (mem. op.).

Morales v. Barnes reminds how an appellate mandate should guide further trial-court proceedings: “Our December 29, 2017 judgment and related mandate, however, rendered a partial judgment dismissing only Barnes’ claims based on the second letter. We affirmed the trial court’s denial of the motion to dismiss Barnes’ claims based on the first letter and we remanded those claims to the trial court for further proceedings. We conclude that by dismissing any claims based on the first letter, the trial court’s order was inconsistent with and failed to give full effect to our December 29, 2017 judgment and related mandate.” No. 05-18-00767-CV (Feb. 7, 2020) (mem. op.)