June 22, 2021

Volume XI, Number 173


June 21, 2021

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Writing For Screen Readers: Start At The Top And Stay There

Thanks to Robert Dubose, who has been kind enough to share his tips on writing for that new, rewired animal, the screen reader. He ought to know.

He wrote the book on the subject.  

We learned about using headings to communicate your argument.

We learned about giving readers that mental ease they need by chunking complex information together and providing regular breaks in the page.

Now, the last installment, which is less aesthetically oriented. Interestingly, it comes back to good compositional technique.

From Robert Dubose

Start with conclusions, then give the support.

Usability studies show that readers are far more likely to read the first sentence of a paragraph than the remainder. That makes it even more important to put your main points at the beginning of paragraphs.

The rest of the sentences in a paragraph should support the main point. As appellate lawyers, we need to list all our support. It is ok if some judges do not read all of the support. If they agree with your main point, they might not need it.

But it is a tragedy if a judge never gets your main point because it is buried at the end of a paragraph.

Avoid hyperlinks.

Hyperlinks are cool. They impress clients. Readers love them. More and more judges ask for them. They allow judges and clerks to follow all sorts of rabbit trails while they are reading your brief.

It is a real shame that they make briefs harder to read. In technology writer Nicholas Carr’s summary of the research on hyperlinks, he concluded, “research continues to show that people who read linear text comprehend more, remember more, and learn more than those who read text peppered with links.” Nicholas Carr, The Shallows 127 (2010).

This makes sense. When you give a hyperlink, you interrupt the flow of your text. You send your reader somewhere else. Of course, as appellate lawyers, we hope that a judge or clerk will look at both sides’ citations. But when they do that while reading our argument, it makes our argument harder to understand.

Copyright © 2021, Hunton Andrews Kurth LLP. All Rights Reserved.National Law Review, Volume I, Number 141



About this Author

Kendall M. Gray, Antitrust Litigation Attorney, Andrews Kurth Law Firm

Kendall is a board certified civil appellate specialist who has represented clients in state and federal appellate courts such as the U.S. Supreme Court, the U.S. Courts of Appeal for the Fifth, Ninth, Tenth and Federal Circuits, the Supreme Court of Texas and many intermediate courts of appeal. His practice includes a variety of complex commercial, medical malpractice and toxic tort matters, as well as a particular focus in disputes involving employee benefits, managed care and ERISA. The disputes commonly require complex written and oral advocacy on such topics as ERISA preemption,...