Argument in Statements of Facts

Appellate advocates regularly wrestle with the task of presenting the facts of a case in a light most favorable to a client without engaging in “argument.” Although there is no bright line separating “argument” from effective advocacy, a review of the decisions...

Effective Use of Headings

The effective use of headings not only organizes the arguments but also assists the reader who loses the thread to get back on track.  Briefs are boring.  Headings allow a reader who loses concentration and dozes off in the middle of a page to go back and pick up...