It’s one of the first things we’re taught in a law school writing class: write to your audience. Clients, other attorneys, trial judges and appellate courts are four possible, and distinct, audiences, and you write differently for each of them.
So insight into what that audience is looking for, and how it approaches your document, is valuable. Professor David Sorkin sets out to provide insight for writers of appellate briefs in his article, Appellate Briefs — A Reader’s Perspective. Its very brief abstract:
Appellate briefs should make a court want to rule in the advocate’s favor, and should make it easy for the court to do so. An effective brief is short and simple. It employs a tone of deference and respect for the court, engaging the reader’s attention while explaining the advocate’s position.
Legal Writing Prof Blog has already read the article and provides some details.