Once again, the topic of footnotes has generated more comments than I usually get (two compared to zero!). I especially thank kiwi for this comment, recommending an Illinois appellate decision as "[a] must-read for anyone handling an appeal in Illinois." I'd say it's a must read for any lawyer who submits anything in writing to any court. The lesson is simple: Obey the court's rules. If the rules say "no footnotes," then don't use footnotes -- not even for citations. Garner himself will tell you that court rules trump anything Garner says.