Utah Table of Authorities: Principal and Reply Briefs

Principal and reply tables have the same content rule

The reproduced paragraph (b) permits the appellant or petitioner to reply only to the facts and arguments raised in the opposing principal brief. It then names required components: contents, authorities, argument, conclusion and certificate of compliance. Its table clause incorporates paragraph (a)(3). This is more explicit than a rule merely authorizing a reply without describing its front matter.

Review the reply as a separate citation set. An authority used only in the principal brief should not remain in the reply’s table just because a template was copied. Conversely, a newly cited authority answering an opponent’s argument should not be omitted because it was absent from the opening table. The requirement describes navigation within each document, not a combined authorities list for the whole appeal.

Universal citations and page references serve different jobs

Utah’s universal citation identifies a decision independently of reporter pagination. A paragraph pinpoint identifies a passage in that decision. Neither is the page number to place in the table’s brief-page column. Keep the full citation in the authority entry and the locations of its use in a separate column. Check citations in standards of review, introductions and footnotes as well as in the argument.

Resolve a full citation and later short forms to the same decision only after checking the underlying authority. Two opinions involving similar parties are not necessarily duplicates. Alphabetize cases and use clear groups for statutes, rules and other authorities; the category labels are an organizational choice, not a claim that the reproduced rule dictates every heading. The quoted table clause does not decide a passim policy. Concrete page references avoid substituting an unverified convention for the text.

PDF review and editable Word output

The DOCX-only route instead creates TA fields and a TOA field for Word for Windows to build and update. Use the PDF route for ordinary editable table text without relying on those Windows fields.