CJI-Civ. 14:30A

You are instructed to answer the following questions. You must all agree on your

answer to each question.

1. Do you find that the plaintiff, (name), is entitled to recover damages from the

defendant, (name), on (insert applicable pronoun) claim of (insert appropriate description, e.g.,

“negligence,” “breach of the warranty of. . . ,” etc.), under Instruction No. (insert the number

assigned in the case to the instruction that sets forth the basic elements of liability for the claim,

as in Instructions 14:1, 14:8, 14:10, 14:13, 14:17, 14:20, or 14:22)?

(Insert additional separately numbered similar paragraphs so as to include all product

liability claims being made against the defendant.)

If your answer to (question No. 1) (all of these questions numbered [insert numbers,

e.g., 1 and 2]) is “no,” then your foreperson shall complete only Special Verdict Form A,

and all jurors must sign it.

On the other hand, if your answer to (question No. 1) (any one or more of questions

numbered [insert numbers]), is “yes,” then you shall answer the following question(s):

2. Do you find that the plaintiff was (negligent) (or) (at fault) in causing (insert

applicable pronoun) own (injuries) (damages) (losses) as set forth in Instruction No. (insert

the number assigned in the case to the instruction that sets forth the basic elements of any form

of comparative fault, e.g., as in Instruction 14:28 or 14:29)?

(Insert, as above in question 2, but in separately numbered questions, any additional

forms of comparative fault.)

If your answer to (question No.) (all of these questions numbered) (insert specific

numbers of questions relating to the comparative fault of plaintiff, e.g., 2, 3, etc.) is “no,” you

shall answer the following question and then your foreperson shall complete only Special

Verdict Form B, and all jurors must sign it.

3. State the total amount of plaintiff’s (injuries) (damages) (losses) under Instruction

No. (insert the number assigned in the case to the instruction that sets forth recoverable

damages) that were caused by the (negligence) (or) (fault) of the defendant.

On the other hand, if your answer to (question No.) (any one or more of questions

numbered) (insert specific numbers of questions relating to the comparative fault of the

plaintiff) is “yes,” you shall answer the following questions, and then your foreperson shall

complete only Special Verdict Form C and all jurors must sign it.

4. State the total amount of plaintiff’s (injuries) (damages) (losses) under Instruction

No. (insert the number assigned in the case to the instruction that sets forth recoverable

damages) that were caused by the combined (negligence) (or) (fault) of the defendant and

by the (negligence) (or) (fault) of the plaintiff.

5. Taking as 100 percent the combined (negligence) (or) (fault) that caused the

plaintiff’s (injuries) (damages) (losses), what percentage was caused by the defendant and

what percentage by the plaintiff?