In this article, the author stresses the importance of using the standard of review in order to advance the arguments on appeal. According to the author, adding a heading entitled "Standard of Review" in a brief and throwing in the two-line quote is a requirement under Rule 28 (a) 9 ( B). The rule states that standard of review is to be set forth under a separate heading placed before the discussion of the issues.
Appellate Practice Newsletter
Zachary C. Bolitho, Using the Standard of Review to Advance Your Arguments on Appeal, Appellate Practice Newsletter, Spring 2012, at 12.