This article confronts what I consider to be a disturbing trend in how Missouri appellate courts are applying Supreme Court Rule 84.04(d). I approach any criticism of this entrenched rule with some caution. Still, as a retired lawyer on inactive status, I no longer feel constrained in how my opinion on this topic might affect clients with pending appeals. This is a fuller version on an abridged article published in the November issue of Missouri Lawyers Media. I have been given permission to post this longer article here.