Building a Table of Authorities for an Idaho Appellate Brief
The Table of Authorities (TOA) is the second table in every Idaho appellate brief, right after the Table of Contents. It lists every authority cited in the brief with the pages where each appears. Judges and clerks genuinely use it — an incomplete or misordered TOA is one of the first tells of a rushed brief.
Standard organization
Group authorities by type, in this order, alphabetized within each group:
- Cases — full Bluebook citation, alphabetical by first party name: Radford v. Van Orden, 168 Idaho 287, 483 P.3d 344 (2021). Idaho cases cite both the Idaho Reports and the Pacific Reporter.
- Statutes — Idaho Code sections in numerical order: Idaho Code § 12-121.
- Rules — appellate, civil, criminal, and evidence rules: I.A.R. 35; I.R.C.P. 56.
- Constitutional provisions — federal, then Idaho: U.S. Const. amend. IV; Idaho Const. art. I, § 17.
- Other authorities — treatises, law review articles, and secondary sources.
Page references must be exact
Each entry lists every page of the brief where the authority is cited. This is where hand-built TOAs fail: a late edit shifts the pagination and suddenly half the references are off by a page. If you build the table manually, it must be the last thing you do before generating the final PDF — and redone after any further edit.
Consistency with the argument
- Every authority cited in the brief must appear in the TOA — and nothing more.
- Use the identical citation form in the table and the text (same reporter volumes, same pin format).
- Short forms in the text (Radford, 168 Idaho at 290) still map back to one full TOA entry.
The automatic alternative
Idaho Brief Formatter extracts every authority from your draft, Bluebook-normalizes the citations, sorts them into the correct groups, and generates the Table of Authorities automatically — in both the DOCX (with updatable fields) and the PDF. Edit the brief and the table stays consistent, so the TOA is never the thing standing between you and filing.