Crafting an Effective Appellate Brief: Strategies for Persuasion and Clarity

Understand the art of appellate brief writing as advocated by Honorable Thomas D. Waterman from the Iowa Supreme Court. The ultimate goal is to persuade the overworked judge by providing a clear and comprehensive brief that wins both heart and mind. Embrace accuracy, brevity, and clarity, while implementing the ABCs of legal writing - Accuracy, Brevity, and Clarity. Remember, proofreading is key to polishing a flawless document that leaves no room for typos, errors, or misstatements of law and facts.

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• Appellate Brief
• Legal Writing
• Persuasion
• Accuracy
• Clarity

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1. APPELLATE BRIEF APPELLATE BRIEF WRITING WRITING By The Honorable Thomas D. Waterman By The Honorable Thomas D. Waterman Justice Justice Iowa Supreme Court Iowa Supreme Court

2. ULTIMATE GOAL ULTIMATE GOAL PERSUASION PERSUASION Remember your audience Remember your audience put yourself in Judge s shoes: Judge s shoes: Judge feels overworked Judge feels overworked Judge wants to do the right thing Judge wants to do the right thing Judge hates to be reversed Judge hates to be reversed Judge reluctant to deny a party his or Judge reluctant to deny a party his or her day in court her day in court Close calls typically won by advocate Close calls typically won by advocate more trusted by the Judge more trusted by the Judge put yourself in 2

3. THE IDEAL BRIEF THE IDEAL BRIEF Provides effortless comprehension Provides effortless comprehension Wins the Judge s heart and mind Wins the Judge s heart and mind Gives a roadmap to desired result Gives a roadmap to desired result Spoon Spoon- -feeds the facts and law so that ruling feeds the facts and law so that ruling practically writes itself practically writes itself Scalia: The overarching objective of a brief Scalia: The overarching objective of a brief is to make the court s job easier. is to make the court s job easier. Combine the ideal brief with a stellar oral Combine the ideal brief with a stellar oral argument. argument. 3

4. PRACTICE THE ABCs PRACTICE THE ABCs Accuracy Accuracy Brevity Brevity Clarity Clarity 4

5. ACCURACY ACCURACY Never misstate the law or the facts Never misstate the law or the facts Comply with the rules: Comply with the rules: Contents of brief Contents of brief Word limits Word limits Format Format Citation form Citation form Deadlines Deadlines Proofread Proofread 5

6. PROOFREAD PROOFREAD Zero tolerance for: Zero tolerance for: Typos Typos Grammar errors Grammar errors Misspellings Misspellings Incorrect citations Incorrect citations 6

7. PROOFREAD PROOFREAD Check Table of Authorities for consistency Check Table of Authorities for consistency Do authority checks: Do authority checks: KeyCite KeyCite cases cases Check quotations Check quotations Be true to the record" Be true to the record" Don t rely 100% on spell check (e.g., Don t rely 100% on spell check (e.g., principle vs. principal) principle vs. principal) 7

8. PROOFREAD PROOFREAD Compare edits (old vs. new draft) Compare edits (old vs. new draft) Borrow another set of eyes Borrow another set of eyes Finish early Finish early well before deadline well before deadline 8

9. BREVITY BREVITY Optimize organization (theme and sequence) Optimize organization (theme and sequence) Make every word count Make every word count Eliminate clutter: Eliminate clutter: Useless detail Useless detail Needless repetition Needless repetition Weak points Weak points Edit unnecessary words Edit unnecessary words Prefer the active voice Prefer the active voice 9

10. LESS IS MORE LESS IS MORE INTERACTIVE EDITING EXERCISE: INTERACTIVE EDITING EXERCISE: Due to the fact that Due to the fact that Because Because In the event that In the event that If If 10

11. LESS IS MORE LESS IS MORE At the same time that was happening At the same time that was happening Meanwhile Meanwhile Provided, however, that Provided, however, that But But Ten million two hundred thousand dollars Ten million two hundred thousand dollars ($10,200,000.00) ($10,200,000.00) $10.2 million $10.2 million 11

12. LESS IS MORE LESS IS MORE The vehicle was operated by the Plaintiff The vehicle was operated by the Plaintiff John Smith drove his Taurus John Smith drove his Taurus Comes Now Comes Now Eliminate it! Eliminate it! Plain English v. Jargon: Plain English v. Jargon: Pursuant to Pursuant to Under Under 12

13. CLARITY CLARITY Scalia: Value clarity above all other elements Scalia: Value clarity above all other elements of style. of style. Use Table of Contents with informative Use Table of Contents with informative headings headings Orient the reader: Orient the reader: Provide context up front Provide context up front Give the big picture so that supporting Give the big picture so that supporting detail falls into place; use themes detail falls into place; use themes Scalia: put question first Scalia: put question first Roadmap w/matching road signs make Roadmap w/matching road signs make reader smart reader smart 13

14. CLARITY CLARITY Consider a Summary of Argument Consider a Summary of Argument Use bullet points/lists Use bullet points/lists Use quotations effectively: Use quotations effectively: Lead in sentence Lead in sentence Don t over Don t over- -quote quote Proper emphasis Proper emphasis Internal citations Internal citations Don t lead with your chin by Don t lead with your chin by omissions omissions 14

15. OTHER TIPS OTHER TIPS Use footnotes effectively: Use footnotes effectively: String citations String citations Tangential issues of possible interest Tangential issues of possible interest Flow Flow Topic sentence Topic sentence Use active voice Use active voice Impact Impact Beginning and end Beginning and end Sentence length Sentence length short after long short after long 15

16. OTHER TIPS OTHER TIPS Eliminate Distractions Eliminate Distractions Abbreviations that must be decoded Abbreviations that must be decoded Awkward sentences Awkward sentences Big words Big words Tough sells Tough sells Specify relief requested Specify relief requested 16

17. OTHER TIPS OTHER TIPS Citations: Citations: Always give jump cites Always give jump cites Give volume and page number with Give volume and page number with short cites short cites Avoid ambiguous Avoid ambiguous id. id. s s Italicize; don t underline case names Italicize; don t underline case names Emphasis Emphasis Italicize sparingly Italicize sparingly 17

18. WRITERS BLOCK WRITER S BLOCK Leading causes Leading causes Unresolved issues or muddled thinking Unresolved issues or muddled thinking Distractions Distractions Feeling overwhelmed Feeling overwhelmed Chicken Chicken egg problems egg problems Remedies Remedies Think it through Think it through Outline first Outline first Write discrete sections (marathon analogy) Write discrete sections (marathon analogy) Checklists Checklists Do something else Do something else Quiet time Quiet time 18

19. PRACTICE POINTERS PRACTICE POINTERS Error Preservation Error Preservation A supreme court is a court of review, not of A supreme court is a court of review, not of first view. first view. State v. Hanes State v. Hanes, 981 N.W.2d 454, 460 (Iowa 2022) (quoting 460 (Iowa 2022) (quoting Ripperger Pub. Info. Bd. Pub. Info. Bd., 967 N.W.2d 540, 552 (Iowa , 967 N.W.2d 540, 552 (Iowa 2021)). 2021)). N.B. Iowa R. Civ. P. 1.904(2) (providing for motions N.B. Iowa R. Civ. P. 1.904(2) (providing for motions to reconsider, enlarge, or amend) to reconsider, enlarge, or amend) Purposes Purposes Give district court chance to correct error. Give district court chance to correct error. See Hanes Hanes, 981 N.W.2d at 458 (noting district court can , 981 N.W.2d at 458 (noting district court can correct its own errors and eliminate need for correct its own errors and eliminate need for appeal). appeal). Give other side chance to respond and make a Give other side chance to respond and make a record. record. See id. See id. at 460 (describing opportunity to fill at 460 (describing opportunity to fill factual gaps in record). factual gaps in record). , 981 N.W.2d 454, Ripperger v. Iowa v. Iowa See 19

20. PRACTICE POINTERS PRACTICE POINTERS Error preservation cont d Error preservation cont d Error not preserved by denial of Error not preserved by denial of MSJ motion for DV/JNOV. motion for DV/JNOV. See Jones v. Glenwood Golf Corp. See Jones v. Glenwood Golf Corp., , 956 N.W.2d 138 956 N.W.2d 138, 142 , 142 43 (Iowa 2021). v. Younger v. Younger, 2023 WL 3632755, at *4 (U.S. 2023) , 2023 WL 3632755, at *4 (U.S. 2023) (holding post (holding post- -trial motion under FRCP 50 not required to trial motion under FRCP 50 not required to preserve error on a purely legal issue resolved at preserve error on a purely legal issue resolved at SJ JNOV limited to grounds asserted in DV motion. JNOV limited to grounds asserted in DV motion. Pavone Pavone v. Kirke v. Kirke, 801 N.W.2d 477, 493 , 801 N.W.2d 477, 493 94 (Iowa 2011). 2011). Don t be too early or too late. Don t be too early or too late. Too early: Too early: Freer v. DAC, Inc. Freer v. DAC, Inc., 929 N.W.2d 685, 687 88 ( 88 (Iowa 2019) (holding filing appeal waived Iowa 2019) (holding filing appeal waived posttrial motion). posttrial motion). Too late: Too late: Valles v. Valles v. Mueting Mueting, 956 N.W.2d 479, 483 84 (Iowa 2021) (holding plaintiff s dismissal of last 84 (Iowa 2021) (holding plaintiff s dismissal of last defendant triggered thirty defendant triggered thirty- -day deadline to appeal). MSJ, must renew in , must renew in 43 (Iowa 2021). But see Dupree But see Dupree SJ). ). 94 (Iowa , 929 N.W.2d 685, 687 , 956 N.W.2d 479, 483 day deadline to appeal). 20

21. PRACTICE POINTERS PRACTICE POINTERS Proofread verdict form as well as jury instructions Proofread verdict form as well as jury instructions We agree with the court of appeals and district court We agree with the court of appeals and district court that Whitlow preserved error notwithstanding her failure that Whitlow preserved error notwithstanding her failure to object to the erroneous verdict form. She had to object to the erroneous verdict form. She had proposed the correct form, all counsel and the court proposed the correct form, all counsel and the court overlooked the error in the verdict form proposed by overlooked the error in the verdict form proposed by McConnaha McConnaha and submitted by the court, and Whitlow and submitted by the court, and Whitlow timely moved for a mistrial or new trial. timely moved for a mistrial or new trial. Whitlow v. McConnaha McConnaha, 935 N.W.2d 565, 570 n.4 (Iowa 2019). , 935 N.W.2d 565, 570 n.4 (Iowa 2019). But see Olson v. BNSF Ry. Co. But see Olson v. BNSF Ry. Co., No. 22 386709, at *3 (Iowa Ct. App. Jan. 25, 2023) (Buller, J., 386709, at *3 (Iowa Ct. App. Jan. 25, 2023) (Buller, J., concurring specially) ( I am concerned that our concurring specially) ( I am concerned that our application of the application of the Whitlow Whitlow footnote . . . invites mischief in this and future litigation. ), this and future litigation. ), further review granted Olson v. BNSF Ry. Co. Olson v. BNSF Ry. Co., No. 22 , No. 22 0587 (Iowa Apr. 27, 2023). 2023). Whitlow v. , No. 22 0587, 2023 WL 0587, 2023 WL footnote . . . invites mischief in further review granted Order, 0587 (Iowa Apr. 27, Order, 21

22. APPELLATE BRIEF APPELLATE BRIEF Before briefing: Before briefing: Determine the record early Determine the record early Ascertain the governing rules early Ascertain the governing rules early Expect no second extension of time or Expect no second extension of time or relief from page limits relief from page limits finish early! Consider seeking Consider seeking Amicus Amicus brief(s) finish early! brief(s) 22

23. APPELLANTS BRIEF (Iowa) APPELLANT S BRIEF (Iowa) See See Iowa R. App. P. 6.903 Iowa R. App. P. 6.903 et. seq. Table of Contents Table of Contents Informative headings and subheadings Informative headings and subheadings should read like a summary of should read like a summary of argument argument Table of Authorities Table of Authorities Organization (cases alphabetically; Organization (cases alphabetically; statutes numerically; other authorities) statutes numerically; other authorities) No jump cites; No jump cites; passim passim et. seq. 23

24. APPELLANTS BRIEF APPELLANT S BRIEF General Pointers: General Pointers: Consistency with abbreviations/citation Consistency with abbreviations/citation form in text form in text Proofreading Proofreading Statement of Issues Statement of Issues Vitally important to frame issues Vitally important to frame issues effectively effectively Statement of the Case Statement of the Case Introductory sentence should orient Introductory sentence should orient reader reader Short procedural history of case Short procedural history of case 24

25. APPELLANTS BRIEF APPELLANT S BRIEF Statement of Facts Statement of Facts Organize thematically Organize thematically Tell a story that fits theme Tell a story that fits theme Quote favorable passages from ruling(s) Quote favorable passages from ruling(s) below below Don t be conclusory or overtly Don t be conclusory or overtly argumentative argumentative let the facts persuade let the facts persuade Use concrete facts; minimize use of Use concrete facts; minimize use of adverbs and adjectives adverbs and adjectives Try of course test Try of course test 25

26. APPELLANTS BRIEF APPELLANT S BRIEF Routing Statement Routing Statement See See Iowa R. App. P. 6.903(2)( Iowa R. App. P. 6.903(2)(d d) & 6.1101 Strategic Considerations Strategic Considerations Preservation of Error Preservation of Error Identify how error was preserved. Iowa R. App. P. Identify how error was preserved. Iowa R. App. P. 6.903(2)( 6.903(2)(g g)(1). )(1). Identify standard/scope of review. Iowa R. App. P. Identify standard/scope of review. Iowa R. App. P. 6.903(2)( 6.903(2)(g g)(2). )(2). How much leeway does the court have? How much leeway does the court have? ) & 6.1101 26

27. APPELLANTS BRIEF APPELLANT S BRIEF Argument Argument Consider a Summary of Argument Consider a Summary of Argument Standard or scope of appellate review Standard or scope of appellate review How much leeway to be given to tribunal below How much leeway to be given to tribunal below Sequence of arguments Sequence of arguments strongest first See See rifle vs. shotgun, rifle vs. shotgun, supra Caselaw selection: Caselaw selection: Cite to both reviewing court and to court of last resort on Cite to both reviewing court and to court of last resort on governing law governing law Look for other decisions by same judge or court Look for other decisions by same judge or court Beware outcome Beware outcome Honor duty to cite adverse authority Honor duty to cite adverse authority String citations (use parentheticals or a lead in sentence or String citations (use parentheticals or a lead in sentence or replace with single case that surveys the field) replace with single case that surveys the field) Unpublished authority Unpublished authority Analyze key cases Analyze key cases strongest first supra 27

28. QUESTIONS OF FIRST QUESTIONS OF FIRST IMPRESSION IMPRESSION Brief the law from other jurisdictions (trend? Brief the law from other jurisdictions (trend? majority rule?) majority rule?) Show how your proposed rule fits with existing Show how your proposed rule fits with existing law (conversely, show how opponent s conflicts) law (conversely, show how opponent s conflicts) Show how policy behind the rule is furthered Show how policy behind the rule is furthered Argue ramifications (slippery slope/flood gates Argue ramifications (slippery slope/flood gates vs. deterrence) vs. deterrence) Get help from Amici Get help from Amici Address Restatement (Third) position Address Restatement (Third) position 28

29. RETAINING PRECEDENT RETAINING PRECEDENT Stare decisis alone dictates continued adherence to our Stare decisis alone dictates continued adherence to our precedent absent a compelling reason to change the law. precedent absent a compelling reason to change the law. Book v. Book v. Doublestar Doublestar Dongfeng Dongfeng Tyre (Iowa 2015). (Iowa 2015). Tyre Co. Co., 860 N.W.2d 576, 594 , 860 N.W.2d 576, 594 From the very beginnings of this court, we have guarded the From the very beginnings of this court, we have guarded the venerable doctrine of stare decisis and required the highest venerable doctrine of stare decisis and required the highest possible showing that a precedent should be overruled before possible showing that a precedent should be overruled before taking such a step. taking such a step. Bd. of Water Works Bd. of Water Works Trs Moines v. Sac Moines v. Sac Cnty Cnty. Bd. of Supervisors . Bd. of Supervisors, 890 N.W.2d 50, 60 61 (Iowa 2017) (quoting 61 (Iowa 2017) (quoting McElroy v. State McElroy v. State, 703 N.W.2d 385, 394 (Iowa 2005)). 394 (Iowa 2005)). Trs. of City of Des . of City of Des , 890 N.W.2d 50, 60 , 703 N.W.2d 385, 29

30. ATTEMPTS TO OVERTURN ATTEMPTS TO OVERTURN PRECEDENT PRECEDENT Argue (1) the earlier decision was wrongly decided and (2) is Argue (1) the earlier decision was wrongly decided and (2) is causing problems or is unworkable. causing problems or is unworkable. Was targeted decision wrongly decided at the time? Dissents? Was targeted decision wrongly decided at the time? Dissents? State v. Kilby State v. Kilby, 961 N.W.2d 374 (Iowa 2021), , 961 N.W.2d 374 (Iowa 2021), overruling State v. Pettijohn Pettijohn, 899 N.W.2d 1 (Iowa 2017). , 899 N.W.2d 1 (Iowa 2017). overruling State v. Scholarly criticism? Minority view? Scholarly criticism? Minority view? Garrison v. New Fashion Pork LLP LLP, 977 N.W.2d 67 (Iowa 2022), , 977 N.W.2d 67 (Iowa 2022), overruling Gacke v. Pork L.L.C. L.L.C., 684 N.W.2d 168 (Iowa 2004). , 684 N.W.2d 168 (Iowa 2004). Garrison v. New Fashion Pork overruling Gacke v. Pork Xtra Xtra, , Has rule led to problems or fallen out of step with other Has rule led to problems or fallen out of step with other developments? developments? Burnett v. Smith Burnett v. Smith, ___ N.W.2d ___ (Iowa 2023), overruling Godfrey v. State overruling Godfrey v. State, 898 N.W.2d 844 (Iowa 2017). , 898 N.W.2d 844 (Iowa 2017). , ___ N.W.2d ___ (Iowa 2023), 30

31. RIFLE VS. SHOTGUN: FACTORS RIFLE VS. SHOTGUN: FACTORS TO CONSIDER TO CONSIDER Don t invite reversible error Don t invite reversible error Maintain credibility (don t use loser argument) Maintain credibility (don t use loser argument) Don t dilute strong arguments with weak ones Don t dilute strong arguments with weak ones Know your audience (will judge split the baby? Know your audience (will judge split the baby? will the opponent give up?) will the opponent give up?) Education value (priming the pump vs. spoiling a Education value (priming the pump vs. spoiling a surprise) surprise) Alternative grounds for affirmance on appeal Alternative grounds for affirmance on appeal Increasing comfort level for desired outcome Increasing comfort level for desired outcome 31

32. CONSIDER SIDE CONSIDER SIDE- -BY COMPARISON OF KEY COMPARISON OF KEY AUTHORITY AUTHORITY BY- -SIDE SIDE Cf. Feeback v. Swift Pork Co., 988 N.W.2d 340, 344 46 (Iowa 2023) with Hausler v. Gen. Elec. Co., 134 F. App x 890, 891 92 (6th Cir. 2005). 32

33. STATUTORY INTERPRETATION STATUTORY INTERPRETATION Every tool in the box Plain text Rules of construction Iowa Code chapter 4 Scalia & Garner, Reading Law: The Interpretation of Legal Texts Drafting history Bill explanations Floor debate (video archive) Some judges disfavor legislative history. See, e.g., State v. Davison, 973 N.W.2d 276, 293 (Iowa 2022) (McDermott, J., concurring specially) ( The practice of mining legislative history for statements that support a favored viewpoint . . . diverts us from our judicial charge: giving effect to the text that lawmakers have adopted and that the people are entitled to rely on. ). 33

34. APPELLANTS BRIEF Short Conclusion Short Conclusion Be specific and clear on relief sought Be specific and clear on relief sought 34

35. APPELLEES BRIEF APPELLEE S BRIEF (Re)frame issues presented for review (Re)frame issues presented for review Statement of Case/Facts Statement of Case/Facts Do own or tell rest of the story ? Do own or tell rest of the story ? Quote favorable parts of ruling(s) below Quote favorable parts of ruling(s) below Standard/Scope of Review Standard/Scope of Review Preservation of Error/Waiver Preservation of Error/Waiver Sequence of Argument Sequence of Argument Conclusion Conclusion 35

36. REPLY BRIEF REPLY BRIEF Refocus reader on your world view (without Refocus reader on your world view (without rearguing initial brief) rearguing initial brief) Scalia: Reply should be self Scalia: Reply should be self- -contained for retro retro- -readers readers Highlight opponent s overt and tacit Highlight opponent s overt and tacit concessions concessions Repair damage to your position Repair damage to your position Distinguish opponent s cases succinctly Distinguish opponent s cases succinctly contained for 36

37. APPENDIX APPENDIX See See Iowa R. App. P. 6.905 Iowa R. App. P. 6.905 Contents must be from record Contents must be from record Index (Table of Contents) Index (Table of Contents) Transcripts Transcripts identify witness on every page identify witness on every page Don t over/under designate Don t over/under designate If not in record, try: If not in record, try: Judicial notice Judicial notice Stipulation Stipulation Argue legislative fact Argue legislative fact Conversion of proof briefs to final briefs Conversion of proof briefs to final briefs 37

38. INTERLOCUTORY APPEALS INTERLOCUTORY APPEALS Better odds if both sides join Better odds if both sides join Focus on standards (granted sparingly Focus on standards (granted sparingly fat chance ) fat chance ) Institutional bias against piecemeal appeals Institutional bias against piecemeal appeals Increased costs Increased costs Disrupts trial court proceedings Disrupts trial court proceedings Increases workload Increases workload Unstated reason Unstated reason -- -- most issues go away through settlement or resolution on other through settlement or resolution on other grounds grounds most issues go away 38

39. INTERLOCUTORY APPEALS INTERLOCUTORY APPEALS Court will want to know: Court will want to know: Why can t it wait? Why can t it wait? Did trial court get it wrong or right? Did trial court get it wrong or right? Best candidates: Best candidates: Dispositive legal issue that is question of first Dispositive legal issue that is question of first impression with split in authority in other impression with split in authority in other jurisdictions jurisdictions Privilege or confidentiality with irreparable harm Privilege or confidentiality with irreparable harm that cannot be cured on appeal after final judgment that cannot be cured on appeal after final judgment Thirty Thirty- -day deadline (but possible to obtain review of day deadline (but possible to obtain review of earlier interlocutory orders that are intertwined). earlier interlocutory orders that are intertwined). See Hammer v. See Hammer v. Branstad Branstad, 463 N.W.2d 86, 89 (Iowa 1990). 1990). , 463 N.W.2d 86, 89 (Iowa 39

40. INTERLOCUTORY APPEALS INTERLOCUTORY APPEALS Consider conditional resistance/cross Consider conditional resistance/cross- - appeal appeal Consider limited remand Consider limited remand Look for similar cases under 28 U.S.C. Look for similar cases under 28 U.S.C. 1292(6). 1292(6). See See Benco Benco Mortgage Co. v. 351 N.W.2d 784, 787 (Iowa 1984).. 351 N.W.2d 784, 787 (Iowa 1984).. Single Single- -justice ruling can be appealed to justice ruling can be appealed to three three- -justice panel. Iowa R. App. P. justice panel. Iowa R. App. P. 6.1002(5) (setting ten 6.1002(5) (setting ten- -day deadline). Mortgage Co. v. Steil Steil, , day deadline). 40

41. APPLICATIONS FOR FURTHER APPLICATIONS FOR FURTHER REVIEW REVIEW Include a statement supporting Include a statement supporting application for further review Iowa R. App. application for further review Iowa R. App. P. 6.1103 P. 6.1103 Focus on grounds in Iowa R. App. P. Focus on grounds in Iowa R. App. P. 6.1103 6.1103 But still argue merits But still argue merits Twenty Twenty- -day deadline day deadline If granted, reversal or modification likely If granted, reversal or modification likely 41

42. PETITIONS FOR REHEARING PETITIONS FOR REHEARING Almost never change outcome Almost never change outcome Court sometimes revises problematic Court sometimes revises problematic language language Seven Seven- -day deadline in the court of day deadline in the court of appeals. Iowa R. App. P. 6.1204. appeals. Iowa R. App. P. 6.1204. Fourteen Fourteen- -day deadline in the supreme day deadline in the supreme court. Iowa R. App. P. 6.1205. court. Iowa R. App. P. 6.1205. 42

43. RESOURCES RESOURCES 1. 1. Scalia & Garner, Making Your Case, The Art of Scalia & Garner, Making Your Case, The Art of Persuading Judges Persuading Judges Strunk & White, The Elements of Style Strunk & White, The Elements of Style Roget s Thesaurus Roget s Thesaurus Webster s (or your favorite dictionary) Webster s (or your favorite dictionary) Black s Law Dictionary Black s Law Dictionary Bartlett s Familiar Quotations Bartlett s Familiar Quotations The Oxford Dictionary of Quotations The Oxford Dictionary of Quotations America s Popular Proverbs and Sayings America s Popular Proverbs and Sayings Blue Book (or Maroon book) but follow the governing Blue Book (or Maroon book) but follow the governing Court Rules ( Court Rules (e.g., e.g., Iowa R. App. P. 6.904(2)) Iowa R. App. P. 6.904(2)) 10. Scalia & Garner, Reading Law: The Interpretation of Scalia & Garner, Reading Law: The Interpretation of Legal Texts Legal Texts 2. 2. 3. 3. 4. 4. 5. 5. 6. 6. 7. 7. 8. 8. 9. 9. 10. 43

44. THANK YOU THANK YOU 44