Appellate Practice: The Dos and Don'ts of Appellate Motion Practice

A motion can protect appellate jurisdiction, correct the record, secure needed time, preserve the status quo—or create an unnecessary distraction. Knowing when to file one, what the court needs to see, and what is unlikely to succeed can make all the difference.

Join Minnesota Court of Appeals staff attorneys Kari Crone and Jeff Simard, together with appellate practitioners Kyle R. Kroll and Adam E. Petras, for a practical, inside look at motion practice before the Minnesota Court of Appeals. The panel will explain how motions are routed and decided, identify recurring problems and misconceptions, and offer concrete guidance for presenting requests efficiently and persuasively.

Topics will include:

• When a motion is necessary—and when it is not
• Why correspondence is no substitute for a properly filed motion
• Extension requests, including what constitutes “good cause”
• Stays pending appeal and stays of appellate proceedings
• Motions concerning the appellate record
• Requests involving oral argument, enlarged briefs, late filings, sealing, and attorneys’ fees
• Common mistakes that can delay consideration or undermine an otherwise valid request

Whether you practice regularly before Minnesota’s appellate courts or handle appeals only occasionally, this program will provide immediately useful guidance for getting procedural requests before the right decision-maker—and giving the court what it needs to rule.

– Adam E. Petras; Hennepin County Attorney’s Office
– Kari T. Crone; Staff Attorney, Minnesota Court of Appeals
– Jeffrey D. Simard; Staff Attorney, Minnesota Court of Appeals