CACI No. 3060

Code, §§ 51, 52)

[Name of plaintiff] claims that [name of defendant] denied

[him/her/nonbinary pronoun] full and equal [accommodations/advantages/

facilities/privileges/services] because of [his/her/ nonbinary pronoun] [sex/

race/color/religion/ancestry/national origin/disability/medical condition/

genetic information/marital status/sexual orientation/citizenship/primary

language/immigration status/[any combination of those characteristics]/

[insert other actionable or protected characteristic or combination of

characteristics]]. To establish this claim, [name of plaintiff] must prove all

of the following:

1. That [name of defendant] [denied/aided or incited a denial

of/discriminated or made a distinction that denied] full and equal

[accommodations/advantages/facilities/privileges/services] to [name

of plaintiff];

2. [That a substantial motivating reason for [name of defendant]’s

conduct was [its perception of] [name of plaintiff]’s [sex/race/color/

religion/ancestry/national origin/ medical condition/genetic

information/marital status/sexual orientation/ citizenship/primary

language/immigration status/[any combination of those

characteristics]/[insert other actionable or protected characteristic or

combination of characteristics]];]

2. [That the [sex/race/color/religion/ancestry/national origin/medical

condition/genetic information/marital status/sexual orientation/

citizenship/primary language/immigration status/[any combination

of those characteristics]/[insert other actionable or protected

characteristic or combination of characteristics]] of a person whom

[name of plaintiff] was associated with was a substantial

motivating reason for [name of defendant]’s conduct;]

3. That [name of plaintiff] was harmed; and

4. That [name of defendant]’s conduct was a substantial factor in

causing [name of plaintiff]’s harm.

New September 2003; Revised December 2011, June 2012; Renumbered from CACI

No. 3020 December 2012; Revised June 2013, June 2016, December 2025