Some obstacles a defendant may encounter in litigating an appeal include waiver of particular issues, the standard of review applied by the appellate court, and the deference given to the district court’s decisions. Issues not raised in the district court may be considered waived, and relief may only be granted in cases of “plain error.” The standard of review varies depending on whether the argument is legal, mixed question of law and fact, or a finding of fact, with varying degrees of deference to the district court’s rulings. Some legal arguments are reviewed for abuse of discretion, which requires showing that the lower court’s decision was not within the range of reasonable judgments.