The majority of briefs on the merits submitted to the Texas Supreme Court are well argued, well supported and finely tuned. That said, the court also sees its fair share of sloppy writing and incoherent arguments. With some thought and planning, lawyers can improve their writing and become better advocates for their clients. The following list of common blunders is in no particular order. It represents my views alone, not that of the judge for whom I work or of the court.

1. Overly verbose statement of facts: The statement of facts should draw the reader into the story behind the controversy and provide a framework for the legal argument. If the reader loses interest before arriving at the argument, then the statement of facts is probably too long.

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