CACI No. 3061

Elements (Civ. Code, § 51.5)

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

[him/her/nonbinary pronoun] full and equal rights to conduct business

because of [name of plaintiff]’s [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] [discriminated

against/boycotted/blacklisted/refused to buy from/refused to

contract with/refused to sell to/refused to trade with] [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/ 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]];]

2. [or]

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

conduct was [its perception of] the

[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]] of [name of

plaintiff]’s [partners/members/stockholders/directors/officers/

managers/superintendents/agents/employees/business associates/

suppliers/customers];]

2. [or]

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

conduct was [its perception of] the

[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]] of a person with

whom [name of plaintiff] was associated;]

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 June 2012; Renumbered from CACI No. 3021 and

Revised December 2012; Revised June 2013, December 2016, December 2025