In V.W. v. G.W., [Ms 2060902] (Ala. Civ. App. Feb. 22, 2008) , the Court of Civil Appeals commented on the adequacy of citation of authority in a brief’s argument, and held that citation to a statute was sufficient to satisfy Ala. R. App. P. 28(a)(10).
In this child custody case, the father asserted that the mother’s brief failed to comply with Ala. R. App. P. 28(a)(10) by failing to cite any cases supporting her arguments on appeal. The Court of Civil Appeals noted that Rule 28(a)(10) required a party’s argument in the brief to include "citations to the cases, statutes, other authorities, and parts of the record relied on." The Court of Civil Appeals then concluded: "We deem the mother’s reliance upon the primary authority — the pertinent dependency statute cited by the juvenile court in its form judgment — sufficient compliance with Rule 28(a)(10) so as to adequately present for review the propriety of that court’s judgment of dependency." Slip. Op. at p. 6, n. 1.