1.   A lower court forgave the debt, but the case went all the way to the Supreme Court.

2.   A lower court has already dismissed their cases.

3.   A lower federal court ruled that, irrespective of the circumstances, such disciplinary action is never permitted without a prior hearing.

4.   By its split vote, the justices upheld a lower court ruling against Lotus.

5.   Despite the wide-ranging ramifications of the misappropriation theory, the lower courts have endorsed it in a number of important rulings.

6.   For such cases the Report argues that legal aid should be available as in the lower courts.

7.   Overturning a lower court, the Eighth Circuit Court of Appeals said the trial should go forward.

8.   She has already lost in the lower courts.

9.   The case is pending before the lower court.