CACI No. 2000

[Name of plaintiff] claims that [name of defendant] trespassed on [his/her/

nonbinary pronoun/its] property. To establish this claim, [name of plaintiff]

must prove all of the following:

1. That [name of plaintiff] [owned/leased/occupied/controlled] the

property;

2. That [name of defendant] [intentionally/, although not intending to

do so, [recklessly [or] negligently]] entered [name of plaintiff]’s

property] [or]

2. [intentionally/, although not intending to do so, [recklessly [or]

negligently]] caused [another person/[insert name of thing]] to

enter [name of plaintiff]’s property];

3. That [name of plaintiff] did not give permission for the entry [or

that [name of defendant] exceeded [name of plaintiff]’s permission];

4. That [name of plaintiff] was [actually] harmed; and

5. That [name of defendant]’s [entry/conduct] was a substantial

factor in causing [name of plaintiff]’s harm.

[Entry can be on, above, or below the surface of the land.]

[Entry may occur indirectly, such as by causing vibrations that damage

the land or structures or other improvements on the land.]

New September 2003; Revised June 2013, May 2020