CJI-Civ. 14:32A

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 first defendant.)

If your answer to (this question) ([all] [both] of these questions) 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 (this question) (any one or more of these

questions), 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.)

3. Do you find that the designated nonparty, (name of first designated nonparty), was

(negligent) (or) (at fault) in causing plaintiff’s (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)? (Yes or

No)

(Insert, as above in question 3, but in separately numbered questions, any additional

forms of comparative fault.)

4. Do you find that the designated nonparty, (name of second designated nonparty),

was (negligent) (or) (at fault) in causing plaintiff’s (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, as in Instruction 14:28 or 14:29)?

(Insert, as above in question 4, but in separately numbered questions, any additional

forms of comparative fault.)

If your answer to all of these questions numbered (insert specific numbers of questions

relating to the comparative fault of plaintiff, and the designated nonparty or nonparties, 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.

5. 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 any one or more of these questions numbered

(insert specific numbers of questions relating to the comparative fault of the plaintiff and the

designated nonparty or nonparties) is “yes,” you shall then answer the following questions,

and your foreperson shall complete only Special Verdict Form C and all jurors must sign

it.

6. 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), if any, of:

a. the plaintiff; and

b. each of the defendants from whom the plaintiff is entitled to recover; and

c. (the designated nonparty) (any one or more of the designated nonparties).

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

plaintiff’s (injuries) (damages) (losses), what percentage was caused by the (negligence) (or)

(fault), if any, of:

a. the plaintiff;

b. each of the defendants from whom the plaintiff is entitled to recover; and

c. (the designated nonparty) (any one or more of the designated nonparties).

You must enter the figure of zero, “0,” for any party or designated nonparty you

have found was not (negligent) (or) (at fault).