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Citing the record on appeal: R., ROA., J.A. and App., court by court

Answered by The Citation Code team

Your appellate brief cites the record dozens of times. Is it "R. 12," "ROA.12," "J.A. 12," "App. 12" or "1-ER-12"? The answer depends on the court, and several circuits spell out the exact characters.

If you file in a court we haven't covered, reply below with its rule.

The team’s answer

Short answer. There is no single national form. The federal rules define the record and tell you when to cite appendix pages, and most circuits then set their own form. Copy the receiving court's form exactly. The Fourth and Fifth Circuits run programs that link record cites written in their format, so a cite in some other shape may not link.

The federal baseline [Requirement]
The record on appeal is the original papers and exhibits filed below, the transcript, and a certified copy of the docket entries. Fed. R. App. P. 10(a).
Pages reproduced in the appendix are cited by appendix page; anything not reproduced, by the original document's page. Fed. R. App. P. 28(e).
With a deferred appendix, briefs may cite record pages, and the appendix later shows those record page numbers in brackets where the pages appear. Fed. R. App. P. 30(c)(2)(A).

Court by court [Jurisdiction-specific]
Fourth Circuit: JA123, JA 123, J.A.123 or J.A. 123 (SA for a supplemental appendix). No volume or line numbers, no "at," and the prefix again before each nonconsecutive page: JA123, JA234. 4th Cir. R. 28(g) and the court's appendix citation guide (June 24, 2025), for cases under formal briefing orders from July 15, 2022 on.
Fifth Circuit, for electronic records on appeal: ROA.123; scattered pages as ROA.123, 145, 156; in consolidated appeals, the record's case number in the middle: ROA.13-12345.123. 5th Cir. R. 28.2.2 and Fifth Circuit Form 1.
Sixth Circuit, in appeals from district courts: the record entry number, a brief title and the Page ID #. 6 Cir. R. 28(a)(1).
Eighth Circuit: R. Doc. 12, at 3 for a district court docket document. A document that is in both the appendix and the docket gets parallel citations: App. 25; R. Doc. 20, at 3. In agency appeals, when the appendix and the administrative record are numbered differently, cite both: App. 101; A.R. 93. 8th Cir. R. 28A(j).
Ninth Circuit: excerpts of record by volume, 1-ER-12, or ER-26–32 when there is only one volume; SER and FER for supplemental and further excerpts; CAR-, AR- and PSR- for Social Security records, immigration records and presentence reports. Every record assertion is supported by an excerpts cite, except undisputed facts offered only for general background; the committee note says direct cites to the underlying record are otherwise prohibited. 9th Cir. R. 28-2.8, 30-1.6.
Tenth Circuit: App. Vol. 2 at 27; with no appendix, ROA, Vol. II, at 6. 10th Cir. R. 28.1(A).
Eleventh Circuit: document number and page. 11th Cir. R. 28-5.
Federal Circuit: Appx123 or SAppx123, with nothing between the prefix and the number, and no line references. This is the form for the parties' briefs and appendices. Fed. Cir. R. 28(f) and the court's Electronic Filing Procedures (May 2025).

Where the objection was made [Jurisdiction-specific]
A Tenth Circuit brief cites where each issue was raised and ruled on and, for an evidence ruling or a jury instruction, where the objection was made and ruled on. 10th Cir. R. 28.1(A)-(B).

Common mistakes
Carrying one circuit's prefix into another court's brief.
"Appx 123" or "Appx.123" in the Federal Circuit; its procedures list both as improper.
Volume numbers in a Fourth Circuit cite, or none in a Tenth Circuit one.
A direct cite to the district court record for a disputed fact in a Ninth Circuit brief.

Read more
The Court Documents chapter (its opening is free to read): https://citationcode.com/book/court-documents (opens in a new tab)
Each federal rule we track, with a link to its official text and the date we last checked it: https://citationcode.com/court-rules/federal (opens in a new tab)
Real court-document citations, each checked against its source: https://citationcode.com/examples/how-to-cite-court-documents (opens in a new tab)

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