Statement of the Case and Facts:
The pro se brief must contain a statement of the facts, but it should not simply restate all the facts. Instead, the parent will limit the statement of the facts to those that are needed to understand the issues raised in the brief. For example, if the parent believes in a dependency proceeding that the record did not reflect that he or she abandoned, abused or neglected the child, the brief will include facts about the acts found in the dependency order that the court relied on in finding the child was abandoned, abused or neglected. In a termination case, if the parent believes that the grounds for termination were not proven, then the statement of the facts should include facts about the ground relied on by the court in making its ruling. Each fact statement in the brief must include a citation to the page in the record where the fact is contained.Summary of Argument:
The summary of the argument is located before the argument in the pro se brief. But it is often written last. It summarizes the argument and does not exceed five pages, although it is usually much shorter. See Fla. R. App. P. 9.210(b)(4). Once the argument is written, the pro se party should pick out the key ideas from the argument and use those key points as the summary of argument. (Or, if the summary of the argument is written first, it can be used as an outline for writing the issues in the argument section).Argument:
A parent can use the outline he or she made to organize the argument into sections for each issue. First, the parent should state the issue. The parent should then give the standard of review for that issue. Next, he or she should explain the general law that applies to that issue, and cite a few cases and statutes that support the argument. The parent should also explain how the facts in the case show that an error was made. Case law and statutes that most closely relate to the issues being raised in the specific appeal should be cited to support the arguments (although it is not generally necessary to cite a large number of cases that say much the same thing, the most relevant cases should be cited). A parent should also be sure to cite to the volume and page number in the appellate record to direct the appellate court to the facts that support his or her case. Finally, the parent should explain what relief or outcome he or she is asking for in the appeal, which is usually for the dependency or termination order to be reversed, and/or for a new trial or hearing.This same procedure is repeated for each issue raised in the pro se brief.
