Professor Joi Montiel of Jones School of Law has published a great article on how an appellate brief can create an obstacle course for judges. Unlike our brave soldiers, judges dislike obstacles. Your brief should provide judges with a clear pathway to your conclusions. Professor Montiel identifies 10 obstacles (again, these are bad things):

1.  A “fat” brief.

2.  Ignoring the standard of review.

3.  A disorganized brief.

4.  A one-sided brief.

5.  Failing to apply the law to your facts.

6.  Drafting a weak summary of the argument. 

7.  Thoughtless block quotations.

8.  Using the wrong format.

9.  Grammar and punctuation errors.

10.  Citation errors. 

To avoid these obstacles, read her article. 

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