Rule 10.Form of Pleadings
Last amended September 1, 2018 · Last verified July 13, 2026
Full Text of Rule 10
Amendment History
Amended June 21, 2018, effective September 1, 2018.
Reporter's Notes
Reporter’s Notes to Rule 10: 1. Section (a) of Rule 10 is identical to FRCP 10(a) and generally follows prior Arkansas law. Superseded Ark. Stat. Ann. § 27-1113 (Repl. 1962) dealt with captions in complaints and superseded Ark. Stat. Ann. § 27-1121 (Repl. 1962) dealt with captions in answers. Also, the use of only one plaintiff, defendant or other party when there are multiple parties was previously permitted by superseded Ark. Stat. Ann. § 27-1121 (1) (Repl. 1962).
2. Section (b) is identical to FRCP 10(b) with the exception of the omission of the phrase "whenever a separation facilitates the clear presentation of the matters set forth" found in the second sentence. This rule makes it mandatory that each claim founded upon a separate transaction or occurrence and each defense other [than] denials be stated in separate counts or defenses. This is consistent with the requirements contained in superseded Ark. Stat. Ann. § 27- 1114 (Repl. 1962) and superseded Ark. Stat. Ann. § 27-1121 (4) (Repl. 1962).
3. The purpose of Section (c) is to permit the incorporation by reference of prior allegations and thus encourage short and concise pleadings.
4. Section (d) marks a deviation from FRCP 10 in that the attachment of exhibits is here made mandatory unless good cause is stated in the pleading to justify their absence. This provision is similar to superseded Ark. Stat. Ann. § 27-1144 (Repl. 1962), except there is no requirement here that the best evidence of a written instrument be filed in the absence of the original. No attempt has been made by the Committee to define good cause which justifies the failure to attach an exhibit to a pleading; instead, the courts are given the discretion to make such determination. It is the intent, however, that exhibits should be attached to pleadings in all but exceptional cases.
Reporter’s Notes (2018 Amendment): Rule 10(a) was amended by adding a new final sentence specifying that to the extent the information is available, all pleadings are to contain the name, bar number, mailing address, telephone number, fax number and email address of the attorney or the self-represented party signing the pleading. The rule does not apply to information the attorney or self-represented party may not have, for example a fac number, email address, or ar number (self-represented). The same information requirement also applies to motions and other papers. See Ark. R. Civ. P. 7(b)(3).
Plain-English Summary
Rule 10(a) requires every pleading to carry a caption with the court's name, the case title, the case number, and a designation of the pleading type under Rule 7(a). A complaint has to name every party in the caption; later pleadings can name just the first party on each side with a shorthand reference to the rest. Since 2018 the rule has also required, to the extent the information is available, that pleadings list the attorney's or self-represented party's name, bar number, mailing address, phone number, fax number, and email address, so opposing counsel and the court can reach the filer without digging through the record.
Rule 10(b) requires each averment to sit in its own numbered paragraph, limited as far as practical to a single set of circumstances, so that later pleadings and orders can refer back to a paragraph by number instead of re-describing it. Claims and defenses arising from separate transactions or occurrences must be broken into separate counts. Rule 10(c) allows a party to adopt statements from elsewhere in the same pleading, or from another pleading or motion, by reference, which keeps filings from having to repeat the same allegations over and over.
Rule 10(d) is the section with the most bite. Any written instrument or document a claim or defense depends on has to be attached as an exhibit to the pleading, unless the pleading shows good cause for leaving it out. The rule does not define what counts as good cause, leaving that call to the trial court, but the Reporter's Notes make clear the drafters expected exhibits to be attached in all but exceptional cases. Once attached, a copy of the instrument becomes part of the pleading for every purpose, so its contents can be considered along with the allegations that reference it.
Frequently Asked Questions
What has to appear in a pleading's caption?
Rule 10(a) requires the court's name, the title of the action, the case number, and a designation of the pleading under Rule 7(a). A complaint must list every party's name in the caption; other pleadings may name only the first party on each side with an indication that other parties exist.
Do I have to attach a contract or other written document to my complaint?
Generally yes. Rule 10(d) requires a copy of any written instrument or document a claim or defense is based on to be attached as an exhibit, unless the pleading shows good cause for its absence.
What if I don't have a copy of the document my claim depends on?
Rule 10(d) does not define good cause, leaving that determination to the trial court's discretion. A pleading should explain why the document is unavailable rather than omitting it, since the drafters intended exhibits to be attached in all but exceptional situations.
Can I incorporate allegations from earlier in my pleading instead of repeating them?
Yes. Rule 10(c) allows statements in a pleading to be adopted by reference elsewhere in the same pleading, in another pleading, or in a motion.
Do pleadings need numbered paragraphs?
Yes. Rule 10(b) requires each averment to be set out in a numbered paragraph limited, as far as practical, to a single set of circumstances, and it requires separate transactions or occurrences to be pled as separate counts.
What contact information must I include on a pleading?
Since the 2018 amendment, Rule 10(a) requires pleadings to include, to the extent available, the signing attorney's or self-represented party's name, bar number, mailing address, telephone number, fax number, and email address.