232 
Indiana University Studies 
The Supreme Court of the United States requires that when 
the error alleged is the admission or rejection of evidence the 
specification of error must quote the full circumstances of the 
evidence ; that if the error assigned is the charge of the court, 
the exact language must be quoted; that if an instruction 
granted or refused is complained of, the instruction must be 
quoted. 
Questions Involved. If not stated before the statement of 
facts, the points, or questions to be decided, or questions of 
law raised in the case, should be set forth, after the assign- 
ment of errors, separately and numbered, in short, pithy 
phrases. As few points as possible should be set forth, but, 
if necessary, these can be subdivided into subheads. The best 
arrangement is to put the strongest point first, the weakest in 
the middle, and the next to the strongest last. 
Argument. A point will not be considered unless a fair 
effort is made to show that the court below was wrong. Hence 
an attorney must argue every point which he cares to have 
an appellate court consider. Counsel should not only show 
the appellate court what the case is about and what the ques- 
tions before it are, but they should aid the court in reaching 
a correct conclusion. To do this they should produce the 
legal principles which they believe applicable and show how 
they should be applied to the facts in the case. All proposi- 
tions of law should be supported by authorities, and stated 
with the utmost fairness and accuracy. If textbooks are cited, 
volume, page, paragraph, and edition should be given. The 
full citation of a case should be given whenever mentioned. 
Cases from other jurisdictions as well as his own should be 
cited. To cite a digest is an unpardonable sin. If a statute 
is relied upon, it should be inserted in full, unless too long, 
when the particular portion involved should be included. The 
argument should close with a clear, forceful summary, re- 
peating the points and the reasons therefor. 
If the questions involved are independent they should be 
kept distinctly separate by the use of numerals. Separate 
arguments frequently consist of a chain of propositions. A 
brief should show the main propositions and the points within 
a main proposition. This can be done both by the use of 
numerals and letters and by the use of different kinds of type. 
