Question juridique clé
Whether a federal reform appeal is admissible when the value in dispute is below CHF 4,000 and the appellant only refers to prior cantonal submissions.
Solution extraite
No. The appellant had to file a separate motivated brief with the notice of appeal; a mere reference to earlier submissions cannot replace the brief required by law.
Motifs extraits
Because the value of the dispute did not reach CHF 4,000, Art. 67 last paragraph OG required an explanatory memorandum. Federal case law held that simple references to cantonal pleadings are insufficient, so the appeal suffered from a formal defect rendering it inadmissible.