# Illinois Points and Authorities: Rule 341(h)(1) Format, Example and How to Build One

> Illinois briefs need “Points and Authorities,” not a standard TOA: Ill. S. Ct. R. 341(h)(1) text, how it differs, an example, and building it in Word.

*Updated: 2026-09-24*

**The short answer:** Illinois reviewing courts do not use a categorized table of authorities. Ill. S. Ct. R. 341(h)(1) requires “a table of contents, including a summary statement, entitled ‘Points and Authorities,’ of the points argued and the authorities cited in the Argument.” It repeats the Argument's point headings and lists, **under each heading**, the authorities “relied upon or distinguished,” with the brief page for each heading and each authority. It is excluded from the page and word limits (Rule 341(b)(1)). The rule is silent on *passim* and does not require alphabetical order. Microsoft Word's Table of Authorities feature cannot produce this layout; practitioners build it with a customized table of contents. This is general formatting guidance, not legal advice. Last verified: 2026-09-24.

**Fast facts**

- Rule: Ill. S. Ct. R. 341(h)(1), the first required part of the appellant's brief. Rule 341 was last amended effective October 1, 2020 (per the Illinois Supreme Court Rules compiled May 29, 2026).
- Court's term: “Points and Authorities.” The rule calls it a “summary statement” included in the table of contents.
- Structure: the Argument's headings and subheadings, with the authorities cited under each one, and a page reference “on which each heading and each authority appear.”
- Appellee's brief: also required (Rule 341(i) excuses other parts, not (h)(1)). Reply brief: “need contain only Argument” (Rule 341(j)).
- Limits: 50 pages or 15,000 words for appellant's and appellee's briefs, 20 pages or 6,000 words for replies. The table of contents and statement of points and authorities are excluded.
- Order within a heading: the current rule text does not specify one. *Passim*: the rule is silent.
- Criminal appeals: the State Appellate Defender's handbook notes the same requirement applies through Rule 612(b)(9).
- Last verified: 2026-09-24.

## What Rule 341(h)(1) says

> “(h) Appellant's Brief. The appellant's brief shall contain the following parts in the order named: (1) A table of contents, including a summary statement, entitled ‘Points and Authorities,’ of the points argued and the authorities cited in the Argument. This shall consist of the headings of the points and subpoints as in the Argument, with the citation under each heading of the authorities relied upon or distinguished, and a reference to the page of the brief on which each heading and each authority appear.” (Ill. S. Ct. R. 341(h)(1))

Three things follow from the text. First, the headings must be the same “as in the Argument”; the Points and Authorities is derived from the Argument, not written separately. Second, the list includes authorities you distinguish, not only those you rely on. Third, both the headings and the authorities carry [page numbers](/table-of-authorities-page-numbers). The committee comments add that the 1981 restructuring made “Points and Authorities” the first part of the brief “so that it might act as a table of contents.”

## Points and Authorities vs. a table of authorities

**How the Illinois format differs from a standard TOA**

| Feature | Illinois Points and Authorities | Standard table of authorities (e.g., FRAP 28(a)(3)) |
| --- | --- | --- |
| Organized by | Argument headings (points and subpoints) | Type of authority (cases, statutes, other) |
| Authority cited under two headings | Listed under each heading, with that heading's pages | Listed once, with every page in the brief |
| Alphabetical order | Not required by the current rule | Cases alphabetical |
| Page numbers for headings | Yes | No (headings are in the table of contents) |
| Authorities distinguished | Expressly included | Included as cited |
| Separate table of contents | The P&A sits inside the table of contents | Separate table of contents and TOA |
| Built with Word's TOA feature? | No | Yes (Windows) |

## Order of authorities under each heading

The current text of Rule 341(h)(1) does not say how to order authorities within a heading. The committee comments describe an earlier version that ranked cases “as near as may be in the order of their importance,” and the Office of the State Appellate Defender's Handbook on Briefs and Oral Arguments (updated 2020) still repeats that phrase. The handbook's own sample layouts list authorities roughly in the order of the pages where they are cited. Either approach is defensible; order of importance follows the older guidance, and page order is easiest to check. Whatever you choose, use it under every heading.

## Example layout

**POINTS AND AUTHORITIES (example; real Illinois authorities, hypothetical headings and page numbers)**

| Point / authority | Page(s) |
| --- | --- |
| **I. THE CIRCUIT COURT ERRED IN DISMISSING THE COMPLAINT UNDER SECTION 2-619 BECAUSE NO AFFIRMATIVE MATTER DEFEATS THE CLAIM** | 8 |
| *Kedzie & 103rd Currency Exchange, Inc. v. Hodge*, 156 Ill. 2d 112 (1993) | 8, 9 |
| 735 ILCS 5/2-619(a)(9) (West 2024) | 8 |
| **A. The standard of review is de novo** | 9 |
| *Kedzie & 103rd Currency Exchange, Inc. v. Hodge*, 156 Ill. 2d 112 (1993) | 9 |
| **B. The well-pleaded facts must be accepted as true** | 10 |
| *Doe v. Coe*, 2019 IL 123521 | 10, 11 |
| **II. THE REGULATIONS DO NOT CREATE A PRIVATE RIGHT OF ACTION, SO DEFENDANT'S ALTERNATIVE GROUND FAILS** | 13 |
| *Vine Street Clinic v. HealthLink, Inc.*, 222 Ill. 2d 276 (2006) | 13, 14 |
| *Doe v. Coe*, 2019 IL 123521 | 15 |

Notice that *Kedzie* and *Doe v. Coe* appear under more than one heading, each time with only that heading's pages. That repetition is the defining feature of the format, and it is what a categorized table cannot express. Citation forms follow Ill. S. Ct. R. 6: cases filed on or after July 1, 2011 take the public-domain citation (“2019 IL 123521”), earlier cases cite the Official Reports (“156 Ill. 2d 112”), and statutes cite the Illinois Compiled Statutes. The “(West 2024)” year parenthetical is the form Illinois opinions use for ILCS citations. The cases are real and used here only to show format.

## Which other states use a similar format

**Points-and-authorities-style requirements (verified)**

| State | Rule | What it requires |
| --- | --- | --- |
| Illinois | Ill. S. Ct. R. 341(h)(1) | Headings as in the Argument, authorities cited under each heading, page for each heading and authority |
| Oklahoma | Okla. Sup. Ct. R. 1.11(d) (as amended, 2022 OK 93) | A subject “index” in which “the cases, alphabetically arranged, text books and statutes with reference to the pages in the brief where they are cited must be set forth under each proposition respectively” |
| Kentucky | Ky. RAP 32 (effective 2023) | A “statement of points and authorities” setting out the contentions in the order argued, with the authorities and brief pages listed under each; RAP 31 excludes it from word and page limits |

Oklahoma differs from Illinois in one respect: its rule requires the cases under each proposition to be alphabetical. Other lists online also name Kansas; we could not confirm a current Kansas rule requiring this format, so it is not included here. Check your court's current rule before relying on any list.

## How to build Points and Authorities manually

Legal Office Guru, a Word training site for legal staff, states that Microsoft Word's Table of Authorities feature “cannot produce a Points & Authorities format,” and describes a workaround: a custom table of contents that draws on two sources at once, heading styles for the points and table entry (TC) fields for the authorities. The steps below follow that method.

**Word method: a table of contents that lists authorities under headings**

- Apply heading styles to every point and subpoint in the Argument (for example Heading 1 for points I, II; Heading 2 for subpoints A, B).
- At each citation, insert a table entry (TC) field containing the full citation, set to a level one below the heading it falls under, so it lists beneath that heading.
- Insert a custom table of contents and, in its options, turn on both styles and table entry fields as sources.
- Title that section “Points and Authorities” (or place it within the table of contents under that title), then update the field after the final edit.
- Proofread: each authority must appear under every heading where it is cited, with only that heading's pages; Word will not merge or de-duplicate them for you.
- Without Word (Pages, [Google Docs](/table-of-authorities-google-docs-pages)), build it by hand: copy the Argument headings, then list each authority under each heading from a page-by-page read of the [final PDF](/table-of-authorities-from-pdf).

> **Common mistake:** filing a categorized table (Cases, Statutes, Other Authorities) in an Illinois reviewing court. **Correct approach:** Rule 341(h)(1) asks for the Argument's headings with the authorities cited under each heading and page references for both. A categorized table can be added, but it does not replace the Points and Authorities.

## If you are representing yourself

The Illinois Supreme Court Commission on Access to Justice publishes a Guide for Appeals to the Illinois Appellate Court (updated June 2024) and a statewide Appellant's Brief form that the Appellate Court must accept. The form has a “Table of Contents and Points and Authorities” page keyed to Rule 341(h)(1) and advises writing the Argument first so the page numbers are known. Illinois Legal Aid Online also explains each part of the brief. Links are in the sources below.

> **Where BriefAuthority fits:** [BriefAuthority](/table-of-authorities-generator) is pre-launch and built to output a categorized Table of Authorities from your final PDF. An Illinois Points and Authorities layout is not planned at launch. If you need one, join early access and tell us; that is how we decide what comes next. [Join early access](/early-access).

## Frequently asked

**What is Points and Authorities in an Illinois brief?**

It is the summary required by Ill. S. Ct. R. 341(h)(1): the Argument's point and subpoint headings, with the authorities “relied upon or distinguished” cited under each heading, and the brief page on which each heading and each authority appears. It is part of the table of contents.

**Is Points and Authorities the same as a table of authorities?**

No. A table of authorities groups authorities by type and lists each one once. Points and Authorities groups them by argument heading, so an authority cited under two headings is listed twice, each time with that heading's pages.

**Does Points and Authorities count toward the Illinois page or word limit?**

No. Rule 341(b)(1) excludes “the Rule 341(h)(1) table of contents and statement of points and authorities,” along with the cover, certificate of compliance, certificate of service and the Rule 342(a) appendix.

**Does the reply brief need Points and Authorities?**

Rule 341(j) says the reply brief “shall be confined strictly to replying to arguments presented in the brief of the appellee and need contain only Argument.” The appellee's brief must include Points and Authorities; Rule 341(i) excuses only other parts.

**Do authorities have to be alphabetical under each heading?**

Not under the current text of Rule 341(h)(1), which does not specify an order. Older guidance ranked cases by importance; the State Appellate Defender's sample layouts list them roughly in page order. Oklahoma, by contrast, requires alphabetical order under each proposition.

**Can Word make Points and Authorities automatically?**

Not with the Table of Authorities feature. The workaround described by Legal Office Guru is a custom table of contents built from heading styles (for the points) and TC table entry fields (for the authorities).

**Can I use passim in Illinois Points and Authorities?**

Rule 341(h)(1) does not mention [*passim*](/passim-table-of-authorities). Because each heading covers only a few pages, listing every page is usually short and always compliant.

**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) — The categorized format most courts use.
- [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 calls it an index.
- [Florida table of citations](/florida-table-of-citations) — Rule 9.210(b)(2) and Rule 9.800 style.
- [New York table of authorities](/new-york-table-of-authorities) — 22 NYCRR 1250.8, Part 500 and Tanbook style.

**Sources**

- [Illinois Supreme Court — Rule 341. Briefs (official PDF)](https://ilcourtsaudio.blob.core.windows.net/antilles-resources/resources/472b82fb-b6bb-4da0-a8e4-a10c5f65afd6/Rule%20341.pdf)
- [Illinois Supreme Court Rules, compiled May 29, 2026 (full PDF, incl. Rule 6 citations)](https://ilcourtsaudio.blob.core.windows.net/antilles-resources/resources/7ae8a196-2a43-4484-9666-43098da60282/S_Ct_Rules_full.pdf)
- [Illinois Courts — Supreme Court Rules](https://www.illinoiscourts.gov/supreme-court-rules/)
- [Office of the State Appellate Defender — Handbook on Briefs and Oral Arguments (updated 2020)](https://osad.illinois.gov/publications/handbook-on-briefs-and-oral-arguments--updated-2020-.html)
- [Oklahoma Supreme Court — In re Amendment of Rule 1.11, 2022 OK 93](https://www.oscn.net/applications/oscn/deliverdocument.asp?citeid=493051)
- [Kentucky Court of Appeals — Appellant Brief checklist (RAP 32)](https://www.kycourts.gov/Courts/Court-of-Appeals/Documents/AppellantBrief.pdf)
- [Kentucky Court Rules — RAP 31 Format and number of briefs (Westlaw, official publisher)](https://govt.westlaw.com/kyrules/Document/N659C1983ECDA11F08C20EEC6EF44B731?viewType=FullText&originationContext=documenttoc&transitionType=StatuteNavigator&contextData=%28sc.Default%29)
- [Legal Office Guru — Hack TOC to create Points & Authorities](https://legalofficeguru.com/hack-toc-to-create-points-authorities/)
- [Illinois Supreme Court Commission on Access to Justice — Guide for Appeals to the Illinois Appellate Court (PDF)](https://ilcourtsaudio.blob.core.windows.net/antilles-resources/resources/6f4fae47-8963-4f2a-9821-9e8e4125fcf5/Guide_for_Appeals_to_the_IL_Appellate_Court.pdf)
- [Illinois approved statewide form — Appellant's Brief (Appellate Court, PDF)](https://ilcourtsaudio.blob.core.windows.net/antilles-resources/resources/2629c603-a7aa-4e76-8095-e2dda5d3dbef/AC%20Appellants%20Brief.pdf)
- [Illinois Legal Aid Online — How to prepare a brief for appellate court](https://www.illinoislegalaid.org/legal-information/how-format-brief-appellate-court)