CACI No. 3922

Child)

If you decide that [name of plaintiff] has proved [his/her/ nonbinary

pronoun] claim against [name of defendant] for the death of [name of

minor], you also must decide how much money will reasonably

compensate [name of plaintiff] for the death of [name of minor]. This

compensation is called “damages.”

[Name of plaintiff] does not have to prove the exact amount of these

damages. However, you must not speculate or guess in awarding

damages.

The damages claimed by [name of plaintiff] fall into two categories called

economic damages and noneconomic damages. Y ou will be asked to state

the two categories of damages separately on the verdict form.

[Name of plaintiff] claims the following economic damages:

1. The value of the financial support, if any, that [name of minor]

would have contributed to the family during either the life

expectancy that [name of minor] had before [his/her/ nonbinary

pronoun] death or the life expectancy of [name of plaintiff],

whichever is shorter;

2. The loss of gifts or benefits that [name of plaintiff] could have

expected to receive from [name of minor];

3. Funeral and burial expenses; and

4. The reasonable value of household services that [name of minor]

would have provided.

Y our award of any future economic damages must be reduced to present

cash value.

[Name of plaintiff] also claims the following noneconomic damages: The

loss of [name of minor]’s love, companionship, comfort, care, assistance,

protection, affection, society, and moral support.

No fixed standard exists for deciding the amount of noneconomic

damages. Y ou must use your judgment to decide a reasonable amount

based on the evidence and your common sense.

[For these noneconomic damages, determine the amount in current

dollars paid at the time of judgment that will compensate [name of

plaintiff] for those damages. This amount of noneconomic damages

should not be further reduced to present cash value because that

reduction should only be performed with respect to future economic

damages.]

Do not include in your award any compensation for the following:

1. [Name of plaintiff]’s grief, sorrow, or mental anguish; or

2. [Name of minor]’s pain and suffering.

In computing these damages, you should deduct the present cash value

of the probable costs of [name of minor]’s support and education.

In deciding a person’s life expectancy, consider, among other factors,

that person’s health, habits, activities, lifestyle, and occupation. Life

expectancy tables are evidence of a person’s life expectancy but are not

conclusive.

[In computing these damages, consider the losses suffered by all plaintiffs

and return a verdict of a single amount for all plaintiffs. I will divide the

amount [among/between] the plaintiffs.]

New September 2003; Revised December 2005, April 2008, December 2009, June