Guide
Record Citations and the Table of Authorities: J.A., ROA, ER, Appx
On this page5 sections
The short answer
Record citations do not go in a table of authorities. FRAP 28(a)(3) asks for “cases (alphabetically arranged), statutes, and other authorities,” and a cite to the joint appendix, the record on appeal, a docket entry or a transcript is none of those: it points to the evidence and filings in this case, not to law. What courts do regulate is the form of record cites in the body of the brief, and several circuits now require exact formats so their software can hyperlink them: “Appx123” in the Federal Circuit, “ROA.123” in the Fifth Circuit, “1-ER-12” in the Ninth, “JA123” or “J.A. 123” in the Fourth, and a “Page ID #” in the Sixth.
Last verified: 2026-09-26. This is formatting guidance, not legal advice; follow your court's current rules.
Why don't record cites go in the table?
The table of authorities indexes the law the brief relies on. FRAP 28(a)(3) defines its contents as “cases (alphabetically arranged), statutes, and other authorities—with references to the pages of the brief where they are cited” (FRAP 28). A cite such as “J.A. 45” or “ECF No. 12” tells the judge where a fact or filing sits in the record of this case. The judge looks those up in the appendix or the record, not in the table. No rule we reviewed asks for record references in the table of authorities, and none of the circuit rules below mentions them in connection with the table. They belong in the body of the brief, in the statement of the case and the argument, where FRAP 28(a)(6) and 28(e) require them.
Two things that look like record cites are real authorities and do go in the table: a published opinion reported in the Federal Appendix (“803 F. App'x 720”) is a case, and a court rule such as Fed. R. App. P. 28 or 5th Cir. R. 28.2.2 is a rule. Don't confuse the Federal Circuit's “Appx123” (a page of the appendix in this appeal) with “F. App'x” (a reporter).
Record citation formats by court
| Court | Rule or guidance | Format | Example |
|---|---|---|---|
| All courts of appeals | FRAP 28(e) | Pages of the appendix; otherwise the page of the original document; “only clear abbreviations” | Answer p. 7; Transcript p. 231 |
| U.S. Supreme Court | Rule 24.1(g) | Joint appendix or record page | App. 12; Record 12 |
| 4th Cir. | Appendix Pagination & Brief Citation Guide (Citelinks) | JA or J.A., optional space, then the page; no dash or colon; repeat the prefix for each page | JA123, J.A. 123, JA123-125, JA123, JA234 |
| 5th Cir. | 5th Cir. R. 28.2.2; Fifth Circuit Form 1 | “ROA” + period + page; consolidated appeals add the case number; transcript lines after a colon | ROA.123; ROA.123-145; ROA.13-12345.123; ROA.143:22-24 |
| 6th Cir. | 6 Cir. R. 28(a)(1) | Brief title, record entry number and the “Page ID #” of the original record | Order, R. 45, Page ID # 1234 (illustrative) |
| 9th Cir. | 9th Cir. R. 30-1.6 | [volume]-ER-[page]; SER and FER for supplemental and further excerpts; single volume omits the number | 1-ER-12; 4-ER-874–76; ER-26–32; 2-SER-51 |
| Fed. Cir. | Fed. Cir. R. 28(f); Electronic Filing Procedures | “Appx” (or “SAppx”) + number, no space or other character | Appx123; SAppx45 |
The Fourth, Fifth and Federal Circuits explain why the format matters: their systems turn a correctly formatted cite into a link to the page. The Fourth Circuit's guide says its Citelinks utility “hyperlinks appendix citations in the briefs to the cited page of the appendix” and requires the standard format (4th Cir. guide, PDF). The Fifth Circuit's Form 1 says the standardized formats “permit a court developed computer program to hyperlink citations” to the electronic record. The Federal Circuit lists wrong appendix references among the common deficiencies behind notices of noncompliance: “All appendix page numbers must be preceded by ‘Appx’ (or ‘SAppx’ for a supplemental appendix) and then the number, without any intervening non-numerical characters or spaces” (Common Questions).
Common forms that break the rules
- Federal Circuit: “Appx 123,” “Appx. 123” or “A123” instead of “Appx123.”
- Fifth Circuit: “ROA 123” or “R. 123” instead of “ROA.123” in an electronic-record case.
- Ninth Circuit: “ER 12” or “2 ER 51, 98” instead of “ER-12” and “2-ER-51, 2-ER-98.” The rule asks for the complete format for each nonsequential page.
- Fourth Circuit: “J. A. 123” (space inside the prefix), “JA-123,” “JA 400, 423” (prefix not repeated) or “JA321-22” (digits dropped).
- Anywhere: “Id.” for a record page in the Fourth Circuit, whose guide says “Do not use id., supra, or infra to cite to appendix pages.”
Worked example: what goes in the table and what stays out
| Brief page | Text in the brief | In the table of authorities? |
|---|---|---|
| 4 | The district court granted summary judgment. ROA.412-418. | No: record on appeal |
| 4 | Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986). | Yes: Cases, page 4 |
| 5 | Smith testified that the gate was open. ROA.143:22-24. | No: transcript page in the record |
| 5 | Fed. R. Civ. P. 56(a). | Yes: Rules, page 5 |
| 6 | Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986); ROA.520. | Anderson yes (page 6); ROA.520 no |
Table of Authorities
From the excerpt above
| Authority | Page(s) |
|---|---|
| Cases | |
| Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) | 6 |
| Celotex Corp. v. Catrett, 477 U.S. 317 (1986) | 4 |
| Rules | |
| Fed. R. Civ. P. 56(a) | 5 |
The three ROA cites are correct and necessary, but they appear only in the body of the brief. The cases are real (Celotex; Anderson); the brief and record pages are illustrative.
Other common record abbreviations
Outside the circuits above, local rules rarely prescribe one format, and briefs use conventional abbreviations: “R.” for record, “Dkt.” or “ECF No.” for a district court docket entry, “Tr.” for a transcript, “App.” or “Pet. App.” for an appendix. FRAP 28(e) allows them as long as they are “clear abbreviations.” State courts have their own forms. Kentucky, for example, cites the certified record as “TR __” and a video record as “VR” with the date and time (Ky. RAP 31(E)(3)-(4)); see Kentucky points and authorities. Whatever the form, the rule for the table is the same: leave record cites out.
How to check record cites before filing
- Search the final PDF for the prefix your court uses (Appx, ROA., ER-, JA) and scan for spaces, periods or dashes the rule forbids.
- Check that the table has no record entries. A table built by marking every citation can pick up “J.A. 45” or “ECF No. 12” as an “other authority.”
- Confirm the appendix exists before the brief cites it. Under Fed. Cir. R. 30(b)(3), designation and pagination must be completed before the appellant files its principal brief.
- Don't mix formats. A brief that says “ROA.123” on one page and “R. 123” on another is harder to check and may not link.
Frequently asked
Do record citations go in a table of authorities?
No. FRAP 28(a)(3) lists cases, statutes and other authorities. A cite to the appendix, record, docket or transcript points to evidence in the case, not to law, so it stays in the body of the brief.
How do you cite the appendix in the Federal Circuit?
As “Appx” followed by the page number with no space or other character, e.g. Appx123, or “SAppx” for a supplemental appendix. Fed. Cir. R. 28(f) points to the format in the court's Electronic Filing Procedures.
What is the Fifth Circuit's ROA format?
“ROA” followed by a period and the page, e.g. ROA.123. Ranges use a dash (ROA.123-145), consolidated appeals add the case number (ROA.13-12345.123), and transcript lines follow a colon (ROA.143:22-24). See 5th Cir. R. 28.2.2 and Fifth Circuit Form 1.
How do you cite the excerpts of record in the Ninth Circuit?
[volume number]-ER-[page number(s)], e.g. 1-ER-12 or 4-ER-874–76. With one volume, omit the number: ER-26–32. Supplemental and further excerpts use SER and FER (9th Cir. R. 30-1.6).
Is “F. App'x” a record citation?
No. The Federal Appendix is a reporter of court opinions, so “803 F. App'x 720” is a case and belongs in the table. The Federal Circuit's “Appx123” is a page of the appendix in your appeal and does not.
Sources
- Cornell LII: FRAP 28 (28(a)(3) table of authorities; 28(e) references to the record)law.cornell.edu
- Supreme Court of the United States: Rules of the Court (2026), Rule 24.1(g) (PDF)supremecourt.gov
- Fourth Circuit: Appendix Pagination & Brief Citation Guide (PDF)ca4.uscourts.gov
- Fifth Circuit: FRAP with 5th Cir. R. & IOPs, as amended Dec. 1, 2025 (5th Cir. R. 28.2.2 and Form 1)ca5.uscourts.gov
- Sixth Circuit: Rules (6 Cir. R. 28(a)) (PDF)ca6.uscourts.gov
- Ninth Circuit: FRAP and Circuit Rules, Dec. 1, 2025 (9th Cir. R. 30-1.6) (PDF)cdn.ca9.uscourts.gov
- Federal Circuit: Rules of Practice, Dec. 1, 2025 (Fed. Cir. R. 28(f), 30(b)) (PDF)cafc.uscourts.gov
- Federal Circuit: Common Questions (appendix page numbers, “Appx” / “SAppx”)cafc.uscourts.gov
- Federal Circuit: Quick Reference, Electronic Filing (May 2025) (PDF)cafc.uscourts.gov
- Supreme Court of Kentucky: Order 2022-49 creating the Rules of Appellate Procedure (RAP 31(E)) (PDF)kycourts.gov
- Cornell LII: Celotex Corp. v. Catrett, 477 U.S. 317 (1986)law.cornell.edu
- Cornell LII: Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986)law.cornell.edu
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