In this chapter, we explore two forms of dissensus. The first is horizontal dissensus, or that which occurs within a three-judge panel on the courts of appeals. Judges signal this form of dissensus by writing separate opinions that take the form of a dissent or concurrence. The second is vertical dissensus, which occurs when a court of appeals panel disagrees with the lower court over the proper resolution of the case. This form of dissensus is observed when the court of appeals reverses the lower court's decision, either in whole or in part.