MISSOURI SUPREME COURT RULE 84.04

84.04 BRIEFS - CONTENTS 

(a) Contents.  The brief for appellant shall contain:

           .  .  . 

           (4) The points relied on;

           .  .  .

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(d) Points Relied On.

(1) Where the appellate court reviews the decision of a trial court, each point shall:

(A) identify the trial court ruling or action that the appellant challenges;

(B) state concisely the legal reasons for the appellant’s claim of reversible error; and

(C) explain in summary fashion why, in the context of the case, those legal reasons support the claim of reversible error.

The point shall be in substantially the following form: “The [name of agency] erred in [identify the challenged ruling or action], because [state the legal reasons for the claim of reversible error, including the reference to the applicable statute authorizing review], in that [explain why, in the context of the case, the legal reasons support the claim of reversible error].”

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(4)  Abstract statements of law, standing alone, do not comply with this rule.  Any reference to the record shall be limited to the ultimate facts necessary to inform the appellate court and the other parties of the issues.  Detailed evidentiary facts shall not be included.

(5) Immediately following each “Point Relied On,” the appellant, relator, or petitioner shall include a list of cases, not to exceed four, and the constitutional, statutory, and regulatory provisions or other authority upon which that party principally relies.

(6)  If a party asserts error relating to damages, the party may assert its material effect on the judgment, including that the judgment is inadequate or excessive, in the same “Point Relied On.”

(e)        Argument.  The argument shall substantially follow the order of “Points Relied On.”. . . The point relied on shall be restated at the beginning of the section of the argument discussing that point.  The argument shall be limited to those errors included in the “Points Relied On.” . . . The argument shall also include a concise statement of the applicable standard of review for each claim of error.  If a point relates to the giving, refusal or modification of an instruction, such instruction shall be set forth in full in the argument portion of the brief.  Long quotations from cases and long lists of citations should not be included.