8.5.13 THE CONCLUSION

At a minimum, your conclusion should tell the court what you want it to do: grant or deny the motion. Many lawyers write only one sentence as a conclusion, as in this example: GOOD EXAMPLE For the foregoing reasons, this Court should grant the defendant’s motion to dismiss.

It can sometimes be effective to make the conclusion more specific to your case. Even if you wish to do so, however, you should usually avoid writing a lengthy conclusion. Instead, you might include one sentence that succinctly states your most fundamental points, and then follow with the specific request for relief. In motion briefs, it can be appropriate to incorporate phrases-that-pay from the standard of review into the conclusion, as in this example:

GOOD EXAMPLE

Title VII does not impose individual liability on supervisors. Therefore, plaintiff has not alleged facts that plausibly give rise to an entitlement to relief against Defendant Zahm under Title VII, and this court should grant Defendant Zahm’s motion to dismiss.

You will sometimes see flowery language in the conclusion, such as “Counsel for the Defendant respectfully requests that the Court grant the motion to dismiss.” Although this language probably does not hurt counsel, it probably does not help, either. Because the words “respectfully submitted” typically appear in the signature block, just below the conclusion, there is probably no need to use “respectfully” in the conclusion itself.