# Authorities Chiefly Relied Upon: The Asterisk in a Table of Authorities

> The 11th Circuit requires asterisks for key authorities; the D.C. Circuit allows them with a set note. Rule text, exact wording and a worked example.

*Updated: 2026-09-26*

**The short answer:** Some courts let, or make, a brief mark the authorities it relies on most with an asterisk in the left margin of the table of authorities. In the **D.C. Circuit** it is optional: D.C. Cir. R. 28(a)(2) says an asterisk “may be placed next to those authorities on which the brief principally relies,” with this note at the bottom of the first page of the table: “Authorities upon which we chiefly rely are marked with asterisks.” In the **Eleventh Circuit** it is required: 11th Cir. R. 28-1(d) says the Table of Citations “shall contain asterisks in the margin identifying the citations upon which the party primarily relies.” FRAP 28 says nothing about asterisks, and we found no other federal circuit rule that mentions them.

Last verified: 2026-09-26. This is formatting guidance, not legal advice; follow your court's current rules.

**Fast facts**

- D.C. Cir. R. 28(a)(2): asterisks optional; if used, the note “Authorities upon which we chiefly rely are marked with asterisks.” goes at the bottom of the first page of the table.
- D.C. Cir. R. 28(a)(2) also bans *passim*: the table “must identify each page of the brief on which the authority is cited.”
- 11th Cir. R. 28-1(d): asterisks required, “in the margin,” for “the citations upon which the party primarily relies.” The rule does not prescribe a note.
- 11th Cir. R. 28-1(d) also bars *passim* and allows page ranges only “if the authority is cited on every page in the range.”
- The Eleventh Circuit calls the table the “Table of Citations.”
- FRAP 28(a)(3) sets the federal baseline and does not mention asterisks.
- The rule texts checked here: D.C. Circuit rules as amended through Dec. 4, 2025; Eleventh Circuit rules effective Aug. 1, 2026.

## What the D.C. Circuit rule says

> “In the left-hand margin of the table of authorities, an asterisk may be placed next to those authorities on which the brief principally relies, together with a notation at the bottom of the first page of the table stating: ‘Authorities upon which we chiefly rely are marked with asterisks.’ Even though the marking of ‘principal authorities’ is optional, the table of authorities must identify each page of the brief on which the authority is cited; passim or similar terms may not be used.” D.C. Cir. R. 28(a)(2).

Three details matter. The asterisk goes in the **left-hand margin**, before the authority, not after the page numbers. The note goes at the **bottom of the first page** of the table, not at the end. And the wording is fixed by the rule, so copy it exactly. The same rule, 28(a)(3), requires a Glossary of abbreviations “on a page immediately following the table of authorities” ([D.C. Circuit Rules, PDF](https://www.cadc.uscourts.gov/sites/cadc/files/rules-RulesFRAP20251204.pdf)).

## What the Eleventh Circuit rule says

> “The Table of Citations shall show the locations in the brief of citations, and shall contain asterisks in the margin identifying the citations upon which the party primarily relies. The Table of Citations should not use the ‘passim’ notation, but should instead list every page on which an authority is cited. Page ranges may be used if the authority is cited on every page in the range (e.g., ‘7-10’ instead of ‘7, 8, 9, 10’).” 11th Cir. R. 28-1(d).

Here the asterisks are mandatory for every principal brief covered by Rule 28-1. The rule does not supply the wording of an explanatory note. Many filers add one anyway so a reader knows what the mark means; the D.C. Circuit wording is a safe choice because it says exactly that. See the [Eleventh Circuit table of citations](/eleventh-circuit-table-of-authorities) page for the rest of Rule 28-1 ([Eleventh Circuit Rules, PDF](https://www.ca11.uscourts.gov/sites/default/files/courtdocs/clk/Rules%20Bookmarked.AUG26.pdf)).

**Asterisk rules compared**

|  | D.C. Circuit | Eleventh Circuit |
| --- | --- | --- |
| Rule | D.C. Cir. R. 28(a)(2) | 11th Cir. R. 28-1(d) |
| Name of the table | Table of authorities | Table of Citations |
| Asterisks | Optional (“may be placed”) | Required (“shall contain”) |
| Which authorities | Those “on which the brief principally relies” | “the citations upon which the party primarily relies” |
| Where | Left-hand margin | In the margin |
| Note | Required with asterisks: “Authorities upon which we chiefly rely are marked with asterisks.” | Not prescribed |
| Passim | Not allowed | Should not be used |

## Worked example

**TABLE OF AUTHORITIES (D.C. Circuit style; real cases, hypothetical page numbers)**

| Authority | Page(s) |
| --- | --- |
| **Cases** |  |
| * *Loper Bright Enterprises v. Raimondo*, 603 U.S. 369 (2024) | 2, 14-17, 22 |
| * *Motor Vehicle Mfrs. Ass'n of U.S., Inc. v. State Farm Mut. Auto. Ins. Co.*, 463 U.S. 29 (1983) | 3, 18-21 |
| *SEC v. Chenery Corp.*, 318 U.S. 80 (1943) | 21 |
| **Statutes** |  |
| * 5 U.S.C. § 706(2)(A) | 3, 18 |

Under the table, at the bottom of its first page, the brief prints: “Authorities upon which we chiefly rely are marked with asterisks.” Read the example the way a judge would: three authorities carry the argument, one is cited once in passing. Every page is listed; ranges such as “14-17” mean the authority is cited on each page in between. In a filed brief the note sits at the bottom of the first page of the table. The cases are real ([Loper Bright](https://www.law.cornell.edu/supremecourt/text/22-451); [State Farm](https://www.law.cornell.edu/supremecourt/text/463/29); [Chenery](https://www.law.cornell.edu/supremecourt/text/318/80)); the page numbers are illustrative.

## How many authorities should get an asterisk?

Neither rule sets a number. Both describe the authorities the brief “principally” or “primarily” relies on, which implies a short list: the cases and statutes the argument cannot stand without. Starring most of the table defeats the purpose. A practical test: if the court read only the starred authorities, would it understand your argument? Keep the stars consistent with the argument itself; an authority starred in the table but cited once in a footnote invites the question why.

## Common errors

- **Leaving out the note in the D.C. Circuit.** The rule ties the asterisks to the notation. Stars without the note do not follow the rule.
- **Paraphrasing the note.** Use the rule's words: “Authorities upon which we chiefly rely are marked with asterisks.”
- **Putting the asterisk after the page numbers** or after the citation. Both rules put it in the margin.
- **No asterisks in an Eleventh Circuit principal brief.** They are required there.
- **Adding *passim* to a starred authority.** Both courts require every page.
- **Stars that did not survive editing.** An authority dropped from the argument keeps its star in the table. Re-check the table against the final brief.

> **Where BriefAuthority fits:** [BriefAuthority](/table-of-authorities-generator) is a free browser tool that builds a table of authorities from your brief's final PDF or .docx. On the review screen you can open any authority and choose “Mark with * (relied on most)”; the exported table then prints the asterisks and the note “* Authorities upon which we chiefly rely are marked with asterisks.” under the table. The Eleventh Circuit preset prompts you to mark them; the D.C. Circuit preset offers them as optional, as its rule does. Move the note to the bottom of the table's first page if your table runs longer than one page. The brief is never uploaded.

## Frequently asked

**What does an asterisk mean in a table of authorities?**

It marks the authorities the brief relies on most. The D.C. Circuit's rule pairs it with the note “Authorities upon which we chiefly rely are marked with asterisks.”

**Is the asterisk required in the D.C. Circuit?**

No. D.C. Cir. R. 28(a)(2) says an asterisk “may be placed” next to principal authorities. If you use asterisks, include the notation at the bottom of the first page of the table.

**Is the asterisk required in the Eleventh Circuit?**

Yes. 11th Cir. R. 28-1(d) says the Table of Citations “shall contain asterisks in the margin identifying the citations upon which the party primarily relies.”

**What is the exact wording of the note?**

“Authorities upon which we chiefly rely are marked with asterisks.” That is the D.C. Circuit's wording. The Eleventh Circuit's rule does not prescribe a note.

**Do other federal courts of appeals use asterisks?**

FRAP 28 does not mention them, and in our review of the circuit rules only the D.C. and Eleventh Circuits address them. Check your court's current local rules before filing.

**Keep reading**

- [Eleventh Circuit table of citations](/eleventh-circuit-table-of-authorities): 11th Cir. R. 28-1(d) in full: asterisks, passim, ranges.
- [Federal courts of appeals: TOA rules](/federal-circuit-table-of-authorities-rules): All 13 circuits compared.
- [Passim in a table of authorities](/passim-table-of-authorities): Which courts ban it and what to write instead.
- [Record citations and the table of authorities](/record-citations-table-of-authorities): Why J.A., ROA, ER and Appx cites stay out of the table.
- [Table of authorities format](/table-of-authorities-format): Categories, dot leaders and page lists.
- [Table of Authorities rules](/table-of-authorities-rules): What FRAP 28 and Rule 34.2 require.

**Sources**

- [U.S. Court of Appeals for the D.C. Circuit: Circuit Rules, as amended through Dec. 4, 2025 (D.C. Cir. R. 28(a)(2)-(3)) (PDF)](https://www.cadc.uscourts.gov/sites/cadc/files/rules-RulesFRAP20251204.pdf)
- [U.S. Court of Appeals for the Eleventh Circuit: Rules, effective Aug. 1, 2026 (11th Cir. R. 28-1(d)) (PDF)](https://www.ca11.uscourts.gov/sites/default/files/courtdocs/clk/Rules%20Bookmarked.AUG26.pdf)
- [Cornell LII: FRAP 28](https://www.law.cornell.edu/rules/frap/rule_28)
- [Cornell LII: Loper Bright Enterprises v. Raimondo, 603 U.S. 369 (2024)](https://www.law.cornell.edu/supremecourt/text/22-451)
- [Cornell LII: Motor Vehicle Mfrs. Ass'n v. State Farm, 463 U.S. 29 (1983)](https://www.law.cornell.edu/supremecourt/text/463/29)
- [Cornell LII: SEC v. Chenery Corp., 318 U.S. 80 (1943)](https://www.law.cornell.edu/supremecourt/text/318/80)