How to Write Effective Argument Headings, by Lisa Solomon, NOW Counsel Network (with hat tip to William P. Statsky!)
Ms. Solomon calls them argument or point headings. I call them propositions. Regardless, their importance as a persuasive writing tool in any brief should never been overlooked.
A proposition or heading is a succinct statement that states the question or issue to be discussed and answered in your brief. If done correctly, the reader – your judge – should follow the logical flow of your brief’s argument by simply reading the propositions and sub-propositions.
A proposition that is a positive statement is more persuasive than a question. Even better, your proposition should state positively what the court ought to do and why. X should happen because of Y or, because of Y, X should happen. Regardless of the format you use, a proposition that says why the court should rule as you want is always more persuasive. -CCE