Combining and splitting PDFs for e-filing
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Courts reject filings for over-merging and under-merging — sometimes in the same standards table. Illinois' rejection standards, effective September 1, 2024, contain both directions as numbered grounds:
- #17 — Multiple documents submitted as one document: "Multiple filings cannot be submitted in a single .PDF file. Please separate the documents and resubmit each separately."
- #18 — Single document submitted as multiple documents: "Please combine all pages of the single document into one .PDF file and resubmit" — with one explicit exception, "where a document must be submitted in multiple PDFs because of the file-size limitations of the EFM."
What counts as "one document"?
That's the entire judgment call, and Illinois' own guidance supplies the test: a motion and its notice of motion are two documents (each its own PDF, each uploaded as a Lead document); exhibits attach to the document they evidence; a single order with all its pages is one. When in doubt, count documents as the hard copy would be counted — the standards derive from paper filing conventions. Michigan's self-help guidance states the same rule with its own exception (summary-proceedings complaints and attachments combine into one file).
Jurisdiction snapshots
| Court | Rule |
|---|
| Illinois (Courts of Review) | #17: never multiple filings in one PDF · #18: never one filing in multiple PDFs (size-limit exception only) · each e-filed document = separate PDF per AOIC guidance |
| NY Appellate Division 1st Dept | Each volume of a multi-volume record/appendix = separate PDF, "shall not be combined into one PDF"; appendix + brief not combined unless combined in the hard copy |
| Ninth Circuit | The opposite pull: brief + required certificates + appendix = one document; each Excerpts of Record volume = one document, ≤ 300 pages; multi-volume sets numbered consecutively |
The pattern: documents are the unit — one PDF per document, volumes are the sanctioned way to split a document that is too big, and nothing bigger than a document gets merged.
What a merge breaks (and the post-merge checklist)
Merging is an edit, and edits have casualties. After any combine:
- Searchable text. Verify Ctrl+F finds known words — a merge involving scanned sections can leave image-only pages; OCR them (scan quality guide).
- Bookmarks. Merges frequently drop or rename bookmarks; NY AD1 returns filings with skeletal bookmarks for correction — rebuild the TOC-mirroring tree (AD1 rules).
- Pagination. Page counters reset; re-stamp so document numbers match the PDF counter, and keep Bates/page numbering continuous across merged sections.
- Size. Re-measure — merging is how files cross the 100 MB lines (NY auto-reject; CA9 cap). If it's over, that's the sanctioned reason to split per Illinois #18.
- Encryption. A locked source page can drag security settings into the merge — re-check (security removal).
Before filing a merged document: one document per PDF · searchable throughout · bookmarks intact and TOC-mirrored · pagination continuous · under the size cap · no security settings inherited.
The checker on this site runs the PDF-mechanics half of that list in seconds.