Supreme courts and other discretionary tribunals grant review in a small fraction of cases. The petition must argue reviewability, not merely error.
The question presented. Written first and rewritten many times. It should be short, neutral in form but framed to your advantage, and answerable in a way that resolves the case.
Reasons for granting review. Conflict among lower courts on the question; an issue of first impression with recurring significance; departure from settled principles; or a decision on an important question that conflicts with the court’s own precedent.
Demonstrating the conflict. Cite the decisions on each side, describe the holdings precisely, and explain why the conflict is real rather than distinguishable on facts. Overstating a shallow conflict is transparent.
Vehicle problems. The court will not take a case where the question was not preserved, where alternative grounds support the judgment, or where the record is unclear. Address these affirmatively; opposing counsel certainly will.
Practical importance. Amicus support at this stage demonstrates that the question matters beyond the parties, and is often the difference.
Length discipline. Petitions are short by rule and should be shorter than permitted. The reasons for granting review should occupy most of the space, and the merits comparatively little.