Not all briefs are created equal. Most are fine. Some are sloppy. A few are unforgettable.

At IACLS, we read a lot of criminal-defense briefs. We write some, we revise others, and we collect the ones that make judges stop and think. When a brief turns the tide—overturns a conviction, earns a reversal, or rewrites how a statute is applied—we ask: why did that one work?

The Common Traits

• Clarity without Concession: The best briefs don’t hedge. They say what the court did wrong, how it matters, and what must happen next.
• Authority with Teeth: Not just string cites, but one or two sharp cases that carry the entire argument—and are explained like you’re teaching, not flexing.
• Structure You Can Follow at a Glance: Paragraphs that punch, not drone. Headers that guide. No wandering, no filler.
• Zero Lawyer Voice: No “comes now the appellant.” No “undersigned counsel respectfully asserts.” Just arguments that move.

What Loses Judges Fast

• Anger without focus – If the brief sounds like a rant, the court tunes out by page two.
• Overstuffed fact sections – Nobody wants a full trial transcript in narrative form.
• Jargon for jargon’s sake – Plain English is not unprofessional. It’s persuasive.

How We Use These Lessons

We curate winning briefs in our internal bank—redacted, tagged, and ready to inspire the next filing. When we help other lawyers with their appeals or motions, we often start by pointing to one of these winning models. It saves time. It sharpens focus. And it increases the odds of a win.

Want to Contribute or Borrow?

Got a brief you’re proud of? Email a redacted copy to friends@iacls.org and we’ll review it for inclusion in the bank.

Need inspiration for your next big motion or PDR? Reach out and ask—we might have something close that cuts straight to the issue.

Good briefs change law. Great ones change lives.