Alaska Civil Pattern Jury Instruction 8.09

The Plaintiff also claims the Defendant was reckless. I will now define recklessness for you. Recklessness by a health care provider means unreasonably disregarding an easily perceptible danger of death or substantial physical harm to a patient. A health care provider [facility] is reckless when [he/she/it] knows or has reason to know of facts that create a high degree of risk of serious physical harm to the patient [but deliberately acts or fails to act, disregarding that risk or acting with indifference to it] [but does not realize or appreciate the high degree of risk involved, although a reasonable health care provider [facility] in [his/her/its] position would]. Recklessness requires an unreasonable disregard of a risk of harm substantially in excess of that necessary to make the conduct negligent.

Recklessness is more than mere inadvertence, incompetence, unskillfulness, or a failure to take precautions to enable the actor to adequately cope with a possible or probable future emergency.