Petition For Writ Of Certiorari - Minnesota Court Of Appeals Page 10
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19Step 8: Prepare your Brief
You have three options for the format of your brief:
(1) Formal Brief: A formal brief includes a table of contents, a statement of the legal issues,
a statement of the case and the facts, an argument, a conclusion, and an addendum. See
Minn. R. Civ. App. P.
128.02. A formal brief must be bound in a specific way, and can’t
just be stapled. See
Minn. R. Civ. App. P. 132.01
(includes the Supreme Court’s order
regarding acceptable types of binding).
(2) Informal Brief: An informal brief may be stapled and must include a written argument
and addendum.
See
Minn. R. Civ. App. P. 128.01, subd.
1. Most applicants for
unemployment benefits file informal briefs.
(3) Memorandum of Law and Short Letter Argument: If you gave a written Memorandum
of Law to the ULJ, you may file that Memorandum as your brief, along with a short letter
argument that addresses the ULJ’s decision. This may be stapled and must include an
addendum. See
Minn. R. Civ. App. P. 128.01, subd.
2.
☐
Choose the format for your brief (formal, informal, or short letter argument).
☐
Write your brief. The Minnesota State Law Library website has helpful information about
writing briefs and example briefs you can read ( ).
☐
Prepare the addendum to your brief. No matter what type of brief you file, your brief must
include an addendum that contains a copy of the ULJ’s decision that you are appealing.
The addendum may also include documents from the record before the ULJ, if there are specific
parts of the record that you want to point out to the Court of Appeals. However, you cannot
include any new evidence that was not presented to the ULJ. If you choose to include
additional documents from the record, the page limit is 50 pages and your addendum should
include a table of contents. See
Minn. R. Civ. App. P. 130.02
for additional instructions about
the addendum.
Revised 12/15/17
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