nomination, and reelection as Texas Governor, two weeks after the Texas Third Court of Appeals halts a District Court Judge's Court of Inquiry into the Willingham case. The Texas Senate ultimately refuses to confirm John Bradley as Texas Forensic Science Commission Chair, but Bradley's appeal to Texas Attorney General Greg Abbott to limit the jurisdiction of the Texas Forensic Science Commission is granted after Bradley's position expires, in July 2011. Attorney General Abbott, whom Perry appointed in 2002, advises the commission that it has no jurisdiction to look into the physical evidence of the Willingham case, and that exceeding jurisdiction would subject commissioners to individual civil liability. (Though the timing remains unmentioned in the film, the opinion is delivered two weeks before Gov. Perry announces his candidacy for President of the United States, and five years after the Forensic Science Commission initially accepted the Willingham/Willis complaint. Also the Attorney General’s office had a representative attending every Forensic Science Commission meeting from its inception, and never previously questioned the body's jurisdiction; Assistant AG Barbara Deane can be seen in meetings documented in the film.) The film looks upon the anti-death penalty movement's seizing upon the case with some skepticism: the primary voices of the film emphasize scientific standards and due process; however they also acknowledge Supreme Court Justice Antonin Scalia's invitation to anti-death penalty groups looking for a case to seize upon: "If such an event had occurred in recent years, we would not have to hunt for it; the innocent's name would be shouted from the rooftops." Production Joe Bailey, Jr., at the time a postdoctoral fellow at the University of Texas School of Law, was enrolled in Steve Mims' film production class at Austin Filmworks. (Mims, well known for instructing generations of noteworthy Austin film talent and as a director of narrative films and short documentaries, teaches at the University of Texas School of Radio Television Film and through Austin Filmworks.) Before Incendiary, Bailey had mostly documented musicians, and had not yet completed a feature-length film. Bailey and Mims had an after-class discussion about clemency in the Texas justice system. Mims recommended David Grann's "Trial By Fire" to Bailey, which had recently been published. Bailey read it, and proposed making a film about Willingham's case. Mims replied, "That would be a lot of work. ... Yeah, let's do it." Mims and Bailey have said that they avoided making a