Iowa R. App. P. 6.904

6.904(1) To the parties. Briefs should minimize references to parties by such designations as

“appellant” and “appellee” and should use the actual names of the parties or descriptive terms

such as “the plaintiff,” “the defendant,” “the employee,” “the injured person,” “the taxpayer,” or

“the decedent.”

6.904(2) To legal authorities.

a. Cases.

(1) When citing cases, parties must use a Bluebook-type citation format that includes the

parties’ names, the volume and page number of the national reporter, a pin cite to the specific

page of the opinion supporting the proposition for which the case is cited, the court issuing

the decision, and the year it was filed. Citations to Iowa cases must be to the North Western

Reporter unless not reported therein, in which case the citation must be to the official reporter.

E.g., ___N.W.2d___, ___ (Iowa ___ ); ___ N.W.2d ___, ___ (Iowa Ct. App___); ___ U.S. ___,

___(___).

(2) Unpublished opinions or decisions. Unpublished opinions or decisions of a court or agency

do not constitute controlling legal authority, but they may be cited as providing persuasive

reasoning.

1. When citing an unpublished opinion or decision, a party must use a Bluebook-type citation

format and include the docket number and a citation to a readily accessible electronic database,

such as Westlaw or LexisNexis, if available. E.g., Smith v. Smith, No. _______, ____ WL

_________, at *___ (Iowa Ct. App. ___ __, ____).

2. If a party cites an unpublished opinion or decision that is not available in a readily

accessible electronic database, such as Westlaw or LexisNexis, the party must file and serve

as an attachment a copy of that opinion or decision with the brief or other paper in which it is

cited. Iowa R. Elec. P. 16.311.

b. Iowa Court Rules. When citing the Iowa Court Rules, parties must use the following

references:

(1) “Iowa R. Civ. P.”; “Iowa R. Crim. P.”; “Iowa R. Evid.”; “Iowa R. App. P.”; “Iowa R.

Remote P.”; “Iowa R. Elec. P.”; “Iowa R. of Prof’l Conduct”; and “Iowa Code of Judicial

Conduct” when citing those rules.

(2) “Iowa Ct. R.” when citing all other rules.

c. Other authorities. When citing other authorities, parties must use a Bluebook-type citation

format. References must be made as follows:

(1) Citations to codes must include the section number and date.

(2) Citations to treatises, textbooks, and encyclopedias must include the edition and the

section or page number as applicable.

(3) Citations to all other authorities must include page numbers.

d. Internal cross-references. Use of “supra” and “infra” is not permitted.

6.904(3) To legal propositions. The following propositions are deemed so well established that

authorities need not be cited in support of them:

a. Findings of fact in a law action are binding upon the appellate court if supported by

substantial evidence.

b. In considering the propriety of a motion for directed verdict, the court views the evidence in

the light most favorable to the party against whom the motion was made.

c. In ruling upon motions for new trial, the district court has a broad but not unlimited

discretion in determining whether the verdict effectuates substantial justice between the parties.

d. The court is less likely to interfere with the grant of a new trial than with its denial.

e. Ordinarily, the burden of proof on an issue is upon the party who would suffer loss if the

issue were not established.

f. In civil cases, the burden of proof is measured by the test of preponderance of the evidence.

g. In equity cases, especially when considering the credibility of witnesses, the appellate court

gives weight to the fact-findings of the district court but is not bound by them.

h. The party who so alleges must, unless otherwise provided by statute, prove negligence by a

preponderance of the evidence.

i. A motorist upon a public highway has a right to assume that others using the road will obey

the law, including statutes, rules of the road, and necessity for due care, at least until the motorist

knows or in the exercise of due care should have known otherwise.

j. Generally questions of negligence and contributory negligence are for the jury; it is only in

exceptional cases that they may be decided as matters of law.

k. Reformation of written instruments may be granted only upon clear, satisfactory, and

convincing evidence of fraud, deceit, duress, or mutual mistake.

l. Written instruments affecting real estate may be set aside only upon evidence that is clear,

satisfactory, and convincing.

m. In construing statutes, the court searches for the legislative intent as shown by what the

legislature said, rather than what it should or might have said.

n. In child custody cases, the first and governing consideration of the courts is the best

interests of the child.

o. Direct evidence and circumstantial evidence are equally probative.

p. Even when the facts are not in dispute or contradicted, if reasonable minds might draw

different inferences from them a jury question is engendered.

6.904(4) To the record.

a. Record citations in briefs.

(1) Citation format. Briefs must contain a citation to the record for each material statement of

fact and case proceeding that identifies the particular part of the record by docket number, title of

document (intelligible abbreviations may be used), reference to the specific pages of the record,

and the filing date. E.g., D0023, M. New Trial at 5 (5/26/2020).

(2) Transcripts. Citations to portions of a transcript must include the docket number assigned

to the transcript as filed, the title of the hearing or event transcribed (intelligible abbreviations

may be used), reference to the specific page(s) of the transcript including page and line

number(s), and the date of the hearing or event that the transcript reported. E.g., D0125, Tr.

Hearing M. New Trial at 125:2–127:14 (6/24/2020).

(3) Exhibits. Citations to exhibits must include the docket number assigned to the exhibit

when admitted (not the docket number assigned when proposed), the number or letter the exhibit

received at the evidentiary hearing or trial, and a concise description of the exhibit. E.g., D0127,

Plaintiff’s Exh. 2, Photograph of Construction Site at 1. If the exhibit is an electronic file

contained on physical media, such as a video file of an interview submitted into evidence on

a DVD, the citation should include a pincite such as a timestamp or other appropriate signifier

when practicable and appropriate, in addition to any docket number associated with the exhibit

on EDMS. E.g., D0129, State’s Exh. 1, DVD of Defendant Interview at 00:30–00:45. Citations

to exhibits are not required to include the date of filing or admission. Citations to an exhibit that

cannot reasonably be maintained electronically, see Iowa R. Elec. P. 16.412(1)(b), that have no

docket number associated with the exhibit, should list the exhibit number or letter received at the

evidentiary hearing or trial, the date of the hearing or trial in which it was admitted, and a concise

description of the exhibit and a notation that no exhibit number is associated with the exhibit.

E.g., State’s Exh. 3, Surveillance Video at 3:31–20:07, 5/26/2024 hearing (no docket number).

(4) Multiple district court cases. In an appeal involving review of more than one district court

docket, the citation to the record must also include the district court docket number. E.g., D0002

(CVCV307586), M.S.J. at 7 (5/26/2020).

(5) District court attachments to filings. If an attachment to a document does not have its own

docket number, a citation to the attachment must refer to the docket number of the document

in addition to the title of the attachment. E.g., Attachment to D0543, Lease Agreement at 5

(3/31/2007).

b. Abbreviations. Subsequent citations to the same filing from the district court may be

abbreviated by reference to the docket number and the corresponding page number. E.g., D0307

at 5.

6.904(5) Hyperlinks and other electronic navigational aids. Hyperlinks and other electronic

navigational aids may be included in an electronically filed document as an aid to the court and

the parties subject to the limitations of Iowa Rule of Electronic Procedure 16.312. A party may

not use hyperlinks or other navigational aids to circumvent any page limitations set by these

rules.