Guide
Pennsylvania Table of Citations: Rules 2174 and 2135
On this page6 sections
- What Rule 2174 actually says
- Roman numerals are optional for the tables, not for the body
- Rule 2135: word limits, certificate thresholds and exceptions
- Illustrative Pennsylvania table of citations
- Build the table from the PDF, review it, then finish in Word
- Pennsylvania errors worth catching before filing
Pennsylvania appellate briefs must contain an alphabetical table of citations immediately after the table of contents. Pa.R.A.P. 2174(b) applies to all briefs, not just the appellant's opening brief. Under Rule 2174(c), the introductory tables may be unnumbered; if you number their pages, use Roman numerals. Rule 2135(b) excludes the tables from the brief's word limit. These are Pennsylvania appellate requirements, not a rule for every trial-court filing. Official rule text checked October 7, 2026.
Open the table of authorities generator to build a table from your paginated PDF, review the authorities and their pages, and download a finished Word table. If you have the matching .docx and a text-based PDF, you can instead insert the finished table into your Word file. Free. No account. Processing stays in your browser.
| Question | Requirement or practical distinction | Source |
|---|---|---|
| Which briefs? | All briefs governed by this appellate rule; there is no short-brief exception in Rule 2174(b). | Pa.R.A.P. 2174(b) |
| What is it called? | Table of citations. | Pa.R.A.P. 2174(b) |
| Where does it go? | Immediately following the table of contents. | Pa.R.A.P. 2174(b) |
| How is it ordered? | Alphabetically. The rule does not prescribe category headings or a separate category sequence. | Pa.R.A.P. 2174(b) |
| Must table pages have numbers? | No. If numbered, the introductory table pages must use Roman numerals: i, ii, iii. | Pa.R.A.P. 2174(c) |
| What about the brief's body? | Arabic page numbers; the reproduced record and supplemental reproduced record have their own numbering with a and b suffixes. | Pa.R.A.P. 2173 |
| Does the table use the word allowance? | No. Tables of contents and citations are excluded supplementary matters. | Pa.R.A.P. 2135(b) |
| Are brief-page references or passim expressly specified? | Neither is expressly addressed in Rule 2174(b). Explicit brief-page references make the table usable; do not mistake that recommendation for quoted rule language. | Rule 2174(b); practical indexing guidance |
What Rule 2174 actually says
“All briefs shall contain a table of citations therein, arranged alphabetically, which shall be set forth immediately following the table of contents.” — Pa.R.A.P. 2174(b)
Use the table to index the legal authorities actually cited in this brief, including authorities outside the argument section. It is not a bibliography of everything researched. An appellee or reply brief needs its own table rather than the appellant's list copied across. The reproduced record has a separate table of contents under Rule 2174(a); that is not a substitute for the brief's table of citations.
Alphabetical arrangement is the rule's express instruction. The illustrative table below uses one alphabetical list. If you use category headings, do not assume that a generator's default cases/statutes/rules layout is a prescribed Pennsylvania format: check the court's instructions and review the arrangement. For the underlying citations, Rule 2119(b) directs readers to Pa.R.A.P. 126. A table preset does not rewrite citations in the brief or establish that an authority may properly be cited.
Roman numerals are optional for the tables, not for the body
Rule 2174(c) gives a precise choice: leave the introductory table pages unnumbered, or number them in Roman numerals. It does not require every brief to display i, ii and iii. Rule 2173 supplies the different rule for the brief's body: Arabic numbers. Keep section breaks and page-number settings intact when inserting a longer table. The table's own page number and the page references within an authority's entry serve different purposes.
For example, a table on introductory page iii may list a case at brief pages 8 and 12. Those references are not PDF viewer positions, reporter page numbers, or reproduced-record pages such as 26a. A citation to “R. 26a” points into the record under Rule 2132; it does not belong in the authority's brief-page column. See the page-number guide for handling front matter when reviewing a PDF.
Rule 2135: word limits, certificate thresholds and exceptions
The ordinary limits are 14,000 words for a principal brief and 7,000 for a reply, unless the appellate court orders otherwise. The 30-page and 15-page figures in Rule 2135(a)(1) are thresholds for a word-count certificate when the brief is prepared on a word processor or typewriter; they are not permission to ignore the word limits. Rule 2135(d) requires a certificate when a brief exceeds the stated page threshold and permits reliance on the word processor's count.
| Brief or proceeding | Word limit | Certificate required when longer than |
|---|---|---|
| Ordinary principal brief / reply brief | 14,000 / 7,000 words | 30 / 15 pages |
| Cross-appeal briefs specified in Rules 2136(b)(2) and (b)(3) | 16,500 words | 35 pages |
| Capital direct appeal: principal / reply | 17,500 / 8,500 words | 38 / 19 pages |
| First capital Post-Conviction Relief Act appeal: principal / reply | 22,500 / 11,250 words | 49 / 24 pages |
Rule 2135(b) excludes supplementary matter, including the cover, tables of contents and citations, proof of service, and addenda containing opinions, signature blocks or similar supplementary matter provided for by the rules. Excluding the table does not exclude citations in the argument. The rule's comment also notes that an appellate court may reduce the word count by general rule or case-specific order. Confirm the particular brief type and any briefing order before certifying the count.
Illustrative Pennsylvania table of citations
This is a formatting illustration for a brief discussing preservation of appellate issues. The authorities are real; the brief-page numbers are invented. It is not a filed brief, a list of authorities you must cite, or advice about the current application of waiver rules. Include each entry only if that authority appears in your own brief.
Table of Authorities
| Authority | Page(s) of brief |
|---|---|
| Commonwealth v. Castillo, 888 A.2d 775 (Pa. 2005) | 9, 12 |
| Commonwealth v. Lord, 719 A.2d 306 (Pa. 1998) | 8–10, 12 |
| Pa.R.A.P. 1925(b) | 4, 8–12 |
| Pa.R.A.P. 2117(c) | 5, 11 |
| Pa.R.A.P. 2119(e) | 11–12 |
Here, 775 and 306 identify the first reporter pages of the cases. The right-hand column identifies pages of the hypothetical brief. A later citation such as “Castillo, 888 A.2d at 780” belongs with the same case, not in a second table entry. If the short form occurs on brief page 12, retain 12 in the table even though 780 is the pinpoint in the reporter.
Build the table from the PDF, review it, then finish in Word
- Establish pagination. Export the near-final brief to PDF with its intended body page numbers. Keep the introductory tables separate from the body numbering. Save the matching .docx if you want the finished table inserted into that file.
- Open the generator and choose Pennsylvania. Drop the PDF into the app, or add the matching .docx and text-based PDF together. The Pennsylvania preset is a starting point for table settings, not a complete Rule 2174 or whole-brief compliance check. It does not create all required PDF bookmarks or automatically restyle the brief's citations.
- Review the authorities against the PDF. Confirm full citations, merge duplicate versions and short forms, and check each listed page against the highlighted source. Review Id. references in context. Add missing rules or other authorities; exclude record references and material that is not an authority cited in the brief.
- Inspect the alphabetical list and page labels. Check the beginning and end of the argument, any separately numbered front matter and repeated citations. Use brief page numbers rather than viewer positions or record-page suffixes. Review the exported arrangement instead of assuming that a category setting supplies the rule's required alphabetical order.
- Export the finished Word table. The PDF route downloads a formatted .docx table to place immediately after the table of contents. With the matching Word file and text-based PDF, choose “Insert the finished table into my Word file.” Inspect the insertion location and the TABLE OF CITATIONS heading in the returned document.
- Export a new PDF and recheck. Insertion can change front matter and, if the document's sections are linked, body pagination. Re-export the completed Word brief, confirm that every table reference still matches a printed brief page, and regenerate from the new PDF if pages moved. Recheck the word-count certificate and separate filing requirements before filing.
On the .docx-only route, BriefAuthority adds Word's TA fields and a TOA field so Word for Windows can build and update the table. That is different from a finished PDF-derived table. For a Mac workflow, use the PDF route or pair the Word file with its text-based final PDF. Scanned PDFs can be processed with on-device OCR on the PDF-only route, but scans are not supported as the PDF companion in Word-plus-PDF mode. Verify every citation and page: indexing does not establish that a case is good law.
Pennsylvania errors worth catching before filing
- Omitting a reply table because the brief is short. Rule 2174(b) says all briefs; it does not state a length exception.
- Putting the table after the argument or reproduced record. Its required location is immediately after the brief's table of contents.
- Using Arabic numbers on numbered introductory tables. Either leave those table pages unnumbered or use Roman numerals under Rule 2174(c). Do not extend Roman numbering into the body governed by Rule 2173.
- Confusing R. 26a with brief page 26. Reproduced-record and supplemental-record numbering are separate. They are not the table's authority locators.
- Treating 30 pages as the ordinary word allowance. Check 14,000 words and the certificate threshold separately; apply the correct exception if the appeal falls within Rule 2135(a)(2)–(4).
- Keeping the old PDF after insertion. The Word file may now paginate differently. Only the newly exported filing PDF can confirm the finished table's locators.
Frequently asked
Does Pennsylvania call it a table of authorities or a table of citations?
Pa.R.A.P. 2174 calls it a table of citations. It performs the familiar table-of-authorities function: an index of the legal authorities cited in the brief. Use the rule's terminology for the heading.
Does a Pennsylvania reply brief need a table of citations?
Yes. Rule 2174(b) says all briefs must contain an alphabetical table of citations immediately after the table of contents. The rule does not exempt replies or short briefs.
Must the table of citations be numbered with Roman numerals?
Only if its pages are numbered. Rule 2174(c) permits introductory tables to be unnumbered; if numbered, use Roman numerals. Rule 2173 separately governs Arabic numbering of the brief's body.
Does the table count toward the Pennsylvania brief word limit?
No. Rule 2135(b) excludes tables of contents and citations as supplementary matter. Ordinary principal and reply limits are 14,000 and 7,000 words, subject to the rule's exceptions and court orders.
Does Rule 2174 expressly require page references or prohibit passim?
Rule 2174(b) requires an alphabetical table and specifies its placement, but does not expressly address either page references or passim. Explicit pages are a useful indexing choice; check any additional court instructions rather than treating the rule's silence as a guarantee of acceptance.
Can I make a Pennsylvania table of citations on a Mac?
Yes. Use the PDF route to download a finished .docx table, or add the matching Word file and text-based PDF to insert a finished table in the Word file. The separate .docx-only TA-field route requires Word for Windows to build and update the table.
Official sources checked October 7, 2026
- Pa.R.A.P. 2174 — Tables of Contents and CitationsAll briefs; alphabetical arrangement; placement; optional Roman-numbered introductory tables.pacodeandbulletin.gov
- Pa.R.A.P. 2135 — Length of BriefsWord limits, special proceedings, supplementary-matter exclusions and certificates. Published text includes the amendment effective January 1, 2025.pacodeandbulletin.gov
- Pa.R.A.P. 2173 — Numbering of PagesBrief, reproduced-record and supplemental-record page numbering.pacodeandbulletin.gov
- Pennsylvania Code, Chapter 21 — Briefs and Reproduced RecordRelated Rules 2119, 2132 and 2136. Check the particular appellate court's rules and briefing orders as well.pacodeandbulletin.gov
General formatting guidance, not legal advice. BriefAuthority indexes and formats authorities; it does not validate their legal effect or guarantee that the brief meets every court rule.
BriefAuthority · free
No account · no upload