and ultimately agreed with the County’s position. See Bull v. City & County of San Francisco, 595 F.3d 964, 977 (9th Cir.2010) (en banc) (overruling Thompson v. City of Los Angeles, 885 F.2d 1439, 1446-47 (9th Cir. 1989); Giles v. Ackerman, 746 F.2d 614, 615 (9th Cir.1984)); Powell v. Barrett, 541 F.3d 1298, 1314 (11th Cir.2008) (enbanc) (overruling Wilson v. Jones, 251 F.3d 1340, 1343 (11th Cir.2001)). 4 . We note preliminarily that it is questionable whether the County has adequately preserved this argument for appeal. The argument was omitted from the statement of the issues and is included in the brief within a subsection devoted to the question of whether hindering apprehension is a minor offense. See Quick Techs., Inc. v. Sage Group PLC, 313 F.3d 338, 343 n. 3 (5th Cir.2002) (<HOLDING>). Nevertheless, because the issue was argued
holding issues not raised in appellate brief are waived holding that an argument raised only in fact section of opening brief and in reply brief is not properly raised holding that issue raised in conclusion of brief but omitted from statement of issues and body of brief was not preserved holding argument not raised in opening brief but raised for the first time in reply brief was waived holding an issue listed in statement of issues on appeal but not addressed in brief is abandoned