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Attorneys sometimes italicize headings, bold them, underline them, or enlarge the font. But virtually everyone tries to distinguish the appearance of headings. Why? Because we all recognize the unique value of headings.

Headings create a semantic context for the reader. Psychologists and linguists explain that readers comprehend and remember better when writers use headings that trigger focus at the earliest possible moment.

With this potential, all legal writers would naturally spend a lot of time thinking about how to focus readers through each heading, right?


Consider how Supreme Court justices use headings, dividing their opinions into sections designated by

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