How to Write Strong Statements of Issues

The Statement of Issues identifies the key legal disputes and questions to be resolved in a case. It provides a legal framework for arguments.

Key Principles for Statements of Issues:

Be concise - Frame issues as specific, narrow questions that can be answered yes/no. Avoid rambling issues.
Number the issues - Numbering each issue makes your statement organized and easy to follow.
Focus on disputed issues - Issues should highlight areas of legal controversy requiring resolution, not settled principles.
Connect issues to facts - Issues should flow logically from the facts and arguments.
Phrase issues neutrally - Do not advocate for one side in framing the issues.
Check precedent - Review how prior courts framed similar issues in previous cases.
Align issues to the standard of review - Appellate issues consider the applicable standards of review.
Consider responsibility - Frame issues the court can resolve based on briefed arguments. Avoid speculative issues.
Cross-check consistency - Ensure the framed issues align with the overall arguments.

An effective Statement of Issues provides a legal framework and roadmap for the court to rule in your favour.