# Florida Table of Citations: Rules 9.210 and 9.800

> Florida appellate briefs need a “table of citations,” not a TOA: Fla. R. App. P. 9.210(b)(2) text, word-count exclusion, Rule 9.800 style, sample entries.

*Updated: 2026-09-24*

**The short answer:** Florida appellate courts call it a **table of citations**, not a table of authorities. Fla. R. App. P. 9.210(b)(2) requires “a table of citations with cases listed alphabetically, statutes and other authorities, and the pages of the brief on which each citation appears,” placed right after the table of contents. The table of citations is **excluded** from the word count (Rules 9.210(a)(2)(E) and 9.045(e)). The rule is silent on *passim* and on the order of categories after cases. Entries should follow the Rule 9.800 uniform citation system, which puts the section symbol first for Florida statutes (“§ 59.041, Fla. Stat.”). This is general formatting guidance, not legal advice. Last verified: 2026-09-24.

**Fast facts**

- Rule: Fla. R. App. P. 9.210(b)(2), in the list of what the initial brief “must contain … in order.” It is item (2), right after the table of contents.
- Florida's term: “table of citations.” The phrase “table of authorities” does not appear in Rule 9.210.
- Required order inside the table: only one rule, cases “listed alphabetically.” Statutes and other authorities follow, with no order specified.
- Answer, reply and cross-reply briefs, and briefs on jurisdiction, also need a table of citations (Rule 9.210(c)–(f)).
- Word limits: 13,000 words for initial and answer briefs, 4,000 for reply briefs, 2,500 for jurisdiction briefs (Rule 9.210(a)(2)). The tables of contents and citations are excluded.
- *Passim*: the rule is silent.
- Citation style: Rule 9.210(h) says “Counsel are requested to use the uniform citation system prescribed by rule 9.800.”
- Last verified: 2026-09-24, against the Florida Bar's published rules and the Florida Supreme Court's amendment opinion SC2023-0145.

## What does Rule 9.210 require in a table of citations?

> “(b) Contents of Initial Brief. The initial brief must contain the following, in order: (1) a table of contents listing the sections of the brief, including headings and subheadings that identify the issues presented for review, with references to the pages on which each appears; (2) a table of citations with cases listed alphabetically, statutes and other authorities, and the pages of the brief on which each citation appears; …” (Fla. R. App. P. 9.210(b))

The same table is required in the other briefs. Rule 9.210(c) says the answer brief “must be prepared in the same manner as the initial brief.” Rules 9.210(d) and (e) say a table of citations “must be included in the same manner as in the initial brief” in reply and cross-reply briefs. Rule 9.210(f) lists a table of citations among the contents of briefs on jurisdiction under Rule 9.120. So every merits brief in a Florida district court of appeal or the Florida Supreme Court has one.

**Florida table of citations at a glance**

| Question | Answer | Where it comes from |
| --- | --- | --- |
| What is it called? | Table of citations | Fla. R. App. P. 9.210(b)(2) |
| Where does it go? | Second item in the brief, right after the table of contents | Rule 9.210(b), “in order” |
| How are cases ordered? | Alphabetically | Rule 9.210(b)(2) |
| Order of statutes and other categories? | Not specified. Pick a consistent hierarchy | Rule is silent |
| Page references? | “the pages of the brief on which each citation appears” | Rule 9.210(b)(2) |
| Counts toward word or page limits? | No, the tables of contents and citations are excluded | Rules 9.210(a)(2)(E), 9.045(e) |
| *Passim* allowed? | Not addressed | Rule is silent |
| Citation format? | Rule 9.800 uniform citation system (requested) | Rule 9.210(h) |

## Does the table of citations count toward Florida word limits?

Computer-generated briefs are limited by words; handwritten or typewritten briefs by pages. Rule 9.210(a)(2)(E) excludes “the cover sheet, the tables of contents and citations, the certificates of service and compliance, and the signature block for the brief's author” from “the word count or page limits.” Rule 9.045(e) repeats the point for the certificate of compliance: “The word count shall exclude words in a caption, cover page, table of contents, table of citations, certificate of compliance, certificate of service, or signature block.” The same sentence says the count “shall include all other words, including words used in headings, footnotes, and quotations.”

**Rule 9.210(a)(2) limits (the table of citations is outside these numbers)**

| Brief | Computer-generated | Handwritten or typewritten |
| --- | --- | --- |
| Brief on jurisdiction | 2,500 words | 10 pages |
| Initial or answer brief | 13,000 words | 50 pages |
| Reply brief | 4,000 words | 15 pages |
| Answer/cross-initial brief | 22,000 words | 85 pages |
| Reply/cross-answer brief | 13,000 words | 50 pages |
| Cross-reply brief | 4,000 words | 15 pages |
| Death-sentence appeals and certain Rule 3.851 appeals (initial or answer) | 25,000 words | 100 pages |

One practical consequence: because the table of citations is not counted, a long table costs nothing against the limit. Moving authorities out of the body does not help either, because every word in the argument, including footnotes, is counted. Rule 9.210(a)(2)(E) also requires that all pages not excluded from the computation be consecutively numbered, which is why the front matter (including the table of citations) is usually numbered separately in roman numerals.

## How does Rule 9.800 change the entries?

Rule 9.800 “applies to all legal documents, including court opinions,” and Rule 9.210(h) asks counsel to use it. Its forms differ from the Bluebook in ways that show up directly in a table of citations. Florida statutes lead with the section symbol: “§ 48.031, Fla. Stat. (2014).” Constitutional provisions lead with the article: “Art. V, § 3(b)(3), Fla. Const.” Even the U.S. Constitution is cited article-first: “Amend. V, U.S. Const.” District court of appeal cases name the district: “(Fla. 3d DCA 1988).” For anything the rule does not cover, Rule 9.800 points to the latest Bluebook and then the Florida Style Manual.

**Rule 9.800 forms you will see in a Florida table of citations**

| Authority type | Rule 9.800 form (examples from the rule) | Effect on the table |
| --- | --- | --- |
| Florida Supreme Court case | *Fenelon v. State*, 594 So. 2d 292 (Fla. 1992) | Alphabetical by case name, as the rule requires |
| District court of appeal case | *Buncayo v. Dribin*, 533 So. 2d 935 (Fla. 3d DCA 1988) | Court and district go in the parenthetical |
| Florida Statutes | § 48.031, Fla. Stat. (2014) | Entries begin with “§”; sort numerically by section, not alphabetically |
| Florida Constitution | Art. V, § 3(b)(3), Fla. Const. | Entries begin with the article number |
| U.S. Constitution | Amend. V, U.S. Const. | Article/amendment first, unlike the Bluebook's “U.S. Const. amend. V” |
| Florida rules | Fla. R. Civ. P. 1.180; Fla. R. Crim. P. 3.850 | Group by rule set, then rule number |
| Everything else | Latest Bluebook, then the Florida Style Manual (Rule 9.800(p)) | Treatises, law reviews, federal regulations |

## Example: a Florida table of citations

**TABLE OF CITATIONS (example; real authorities, hypothetical page numbers)**

| Citation | Page(s) |
| --- | --- |
| **Cases** |  |
| *Applegate v. Barnett Bank of Tallahassee*, 377 So. 2d 1150 (Fla. 1979) | 9, 14 |
| *Buncayo v. Dribin*, 533 So. 2d 935 (Fla. 3d DCA 1988) | 11 |
| *Dade Cty. Sch. Bd. v. Radio Station WQBA*, 731 So. 2d 638 (Fla. 1999) | 12-13, 16 |
| *Fenelon v. State*, 594 So. 2d 292 (Fla. 1992) | 7 |
| **Constitutional Provisions** |  |
| Art. V, § 3(b)(3), Fla. Const. | 1 |
| **Statutes** |  |
| § 59.041, Fla. Stat. (2025) | 15 |
| **Rules** |  |
| Fla. R. App. P. 9.045(e) | 18 |
| Fla. R. App. P. 9.210(b)(2) | 18 |

The cases are alphabetical, which is the only ordering Rule 9.210(b)(2) imposes. The category order after cases (constitutional provisions, statutes, rules) is a common convention, not a Florida requirement. Case names are italicized; Rule 9.800(q) says case names “shall be underscored or italicized.” *Applegate* (the appellant's burden to provide an adequate record) and *Dade County School Board v. Radio Station WQBA* (the “tipsy coachman” doctrine) are Florida Supreme Court decisions frequently cited in Florida appellate briefs; here they only illustrate format.

> **Common mistake:** titling the section “Table of Authorities” and ordering Florida statutes alphabetically by the words “Fla. Stat.” **Correct approach:** title it “Table of Citations” as Rule 9.210(b)(2) does, list cases alphabetically, and sort statutes by section number (§ 57.105 before § 59.041 before § 768.79).

## The unique Florida element: certifying that your authorities exist

Florida Rule of General Practice and Judicial Administration 2.515(d)(2), as the Fifth District Court of Appeal's notice to filers explains, requires the signer of a document to represent that “the legal authorities identified herein exist and are accurately cited,” and allows sanctions for filings inconsistent with that representation. The table of citations is the natural checklist for that certification: every authority in it should be one you have pulled and read. A tool that formats or indexes the table does not make that check for you.

**Florida table of citations checklist**

- Title the section “Table of Citations,” placed immediately after the table of contents.
- Cases in alphabetical order; every entry carries the brief pages where it appears.
- Statutes in Rule 9.800 form (“§ 59.041, Fla. Stat. (2025)”), sorted by section number.
- Short forms and [Id.](/id-supra-table-of-authorities) references credited to the full citation's entry, not listed separately.
- No [passim](/passim-table-of-authorities) unless you have a reason; the rule is silent, and listing every page is always compliant.
- Confirm the word count excludes the tables of contents and citations, and that the certificate of compliance says so.
- Check every authority exists and is accurately cited before signing (Fla. R. Gen. Prac. & Jud. Admin. 2.515(d)(2)).

## If you are representing yourself

The Appellate Practice Section of The Florida Bar publishes a free Pro Se (Self-Represented) Appellate Handbook, and the Third District Court of Appeal publishes an information sheet for people who do not have a lawyer. Both explain the brief's parts, including the table of citations. Links are in the sources below.

> **Where BriefAuthority fits:** [BriefAuthority](/table-of-authorities-generator) is a free browser app that drafts a categorized table from your [final PDF](/table-of-authorities-from-pdf), with pages taken from the filed pages, for review before .docx export. Its Florida preset uses the heading “Table of Citations.” The brief is not uploaded. It does not check citations. [Build the table from your PDF](/table-of-authorities-generator) (free, no account).

## Frequently asked

**Is a table of citations the same as a table of authorities?**

Yes in function, different in name. Florida's Rule 9.210(b)(2) calls it a “table of citations” and requires cases listed alphabetically, statutes and other authorities, with the brief pages where each appears. Use Florida's term in a Florida appellate brief.

**Does the table of citations count toward the Florida word limit?**

No. Rule 9.210(a)(2)(E) excludes “the tables of contents and citations” from the word count or page limits, and Rule 9.045(e) says the word count “shall exclude words in a … table of citations.”

**Can I use passim in a Florida table of citations?**

Rule 9.210 does not mention *passim*. Because the rule asks for “the pages of the brief on which each citation appears,” listing every page is the safest reading. If you use *passim*, apply one threshold consistently.

**Do reply briefs in Florida need a table of citations?**

Yes. Rule 9.210(d) says a table of contents, a table of citations, a certificate of service and, for computer-generated briefs, a certificate of compliance “must be included in the same manner as in the initial brief.”

**How do I cite a Florida statute in the table of citations?**

Rule 9.800(f) uses the form “§ 48.031, Fla. Stat. (2014).” The section symbol comes first, so statutes are sorted by section number rather than alphabetically.

**Is Rule 9.800 mandatory for briefs?**

Rule 9.800 says it “applies to all legal documents,” and Rule 9.210(h) says “Counsel are requested to use the uniform citation system prescribed by rule 9.800.” Treat it as the expected format for a Florida appellate brief.

**Keep reading**

- [Table of authorities rules by state](/table-of-authorities-by-state): What each state calls the table and what it requires.
- [Table of authorities rules](/table-of-authorities-rules): FRAP 28, Supreme Court Rules 24 and 34.2, Id. and supra.
- [Passim in a table of authorities](/passim-table-of-authorities): When courts allow it and when they do not.
- [Table of authorities order](/table-of-authorities-order): Category order and sorting inside each category.
- [When is a table of authorities required?](/when-is-a-table-of-authorities-required): Thresholds by court and brief type.
- [California table of authorities rules](/california-table-of-authorities-rules): Cal. Rules of Court and California Style Manual.
- [Texas index of authorities](/texas-index-of-authorities): Texas uses a different name too.
- [New York table of authorities](/new-york-table-of-authorities): 22 NYCRR 1250.8, Part 500 and Tanbook style.
- [Illinois Points and Authorities](/illinois-points-and-authorities): Rule 341(h)(1): authorities listed under each heading.

**Sources**

- [The Florida Bar: Rules of Court Procedure (Florida Rules of Appellate Procedure, official PDF)](https://www.floridabar.org/rules/ctproc/)
- [Florida Rules of Appellate Procedure, July 1, 2026 edition (The Florida Bar, PDF)](https://www-media.floridabar.org/uploads/2026/06/Appellate-Court-Rules-07-01-26.pdf)
- [Supreme Court of Florida, In re Amendments to Florida Rules of Appellate Procedure 9.148 and 9.210, No. SC2023-0145 (word-limit amendments, eff. Jan. 1, 2024)](https://www.floridalawweekly.com/forms/sc2023-0145.pdf)
- [Florida Style Manual: Fla. R. App. P. 9.800 (Uniform Citation System)](https://www.floridastylemanual.com/florida-rule-of-appellate-procedure-9800)
- [Fifth District Court of Appeal: notice on Rule 2.515(d)(2) (authorities exist and are accurately cited)](https://5dca.flcourts.gov/)
- [The Florida Bar Appellate Practice Section: The Pro Se Handbook](https://flabarappellate.org/the-pro-se-handbook/)
- [Third District Court of Appeal: Information for Persons Who Do Not Have a Lawyer (PDF)](https://flcourts-media.flcourts.gov/content/download/535291/file/Pro%20Se%20Information%20(English)%20July%202019%20revision%20(2).pdf)