CJI-Civ. 22:25

Plaintiff, (name), has the burden of proving, by a preponderance of the evidence, the

nature and extent of (insert applicable pronoun) damages. If you find in favor of the

plaintiff, you must determine the total dollar amount of plaintiff’s damages, if any, that

were caused by the publication of the statement(s) by the defendant(s), (name[s]), (and the

[insert appropriate description, e.g., “negligence”], if any, of any designated nonparties).

In determining these damages, you shall consider the following:

1. Any noneconomic losses or injuries plaintiff has had to the present time or which

plaintiff will probably have in the future, including: damage to the plaintiff’s reputation,

physical and mental pain and suffering, inconvenience, emotional stress, fear, anxiety,

embarrassment, humiliation, impairment of quality of life, and [insert any other recoverable

noneconomic losses for which there is sufficient evidence].

2. Any economic losses plaintiff has had to the present time or will probably have in

the future, including: loss of earnings or income; ability to earn money in the future;

(reasonable and necessary) medical, hospital and other expenses, loss of or injury to (insert

applicable pronoun) credit standing, and [insert any other recoverable economic losses for

which there is sufficient evidence].

(If you find in favor of the plaintiff, but do not find any actual damages, you shall

award [insert applicable pronoun] nominal damages of one dollar.)