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.
FAQ
Why was my filing rejected for combining documents?
Illinois rejection standard #17: 'Multiple filings cannot be submitted in a single .PDF file' — each document must be its own PDF. The mirror image, #18, rejects a single document split across multiple PDFs, unless EFM file-size limits force the split.
Do NY AD1 volumes get combined into one PDF?
No. Each volume of a multi-volume record or appendix must be e-filed as a separate PDF — a three-volume record is three PDFs — and the appendix and brief are not combined unless they are combined in the hard copy.
What can go wrong when merging PDFs for filing?
Merges can drop bookmarks, break searchable text layers, reset pagination, and push the file over size limits. After any merge: re-check text searchability, rebuild/verify bookmarks, confirm page numbering continuity and re-measure the size.