It should come as no surprise to attorneys who practice litigation that a large number of trial court decisions on contested matters fall within the discretion of the trial court judge. However, the effects of that fact are often somewhat unclear or overstated. It may seem like a trial court judge's ruling on an issue on which the judge has discretion means the absolute end of the inquiry. But while trial court discretion certainly presents a hurdle to a party seeking to challenge the decision on appeal, it is not always insurmountable.