The big theme of the brief is that Minor was given a first trial in which he was acquitted on some charges and the jury hung on others, that in the second trial the judge made very critical unexplained changes in rulings, and there was a conviction. Among the unexplained changes in rulings:
a decision to refuse to instruct the jury that, to prove bribery, there had to be proof of a quid pro quo– some sort of exchange for the payment. This exact issue is a major one in the Siegelman case.
a decision to refuse to allow proof that Minor had done these sorts of guarantees before in other contexts, proof that had been allowed in the first trial.
a decision to refuse to allow proof (also allowed in the first trial) that the result in the two cases was a reasonable and proper result, and that the Minor firm had done hard work for the result and had major expertise in these areas.
The brief then goes on the attack the sentence and concludes by asking that on remand the case be reassigned to another judge. The last issue is a sustained attack on Judge Wingate based not on the record in this case but on media accounts, particularly from Scott Horton at Harper’s. There are even cites to the LegalSchnauzer blog, the Raw Story web page, and a Jackson Free Press article.