CJI-Civ. 24:1

For the plaintiff, (name), to recover from the defendant, (name), on (insert applicable

pronoun) claim of intentional interference with contract, you must find that all of the

following have been proved by a preponderance of the evidence:

1. The plaintiff had a contract with (name of third person) in which (name of third

person) agreed to (describe the substance of the promise the defendant allegedly interfered

with);

2. The defendant knew or reasonably should have known of the contract;

3. The defendant by words or conduct, or both, intentionally (caused [name of third

person] [not to perform] [to terminate] [insert applicable pronoun] contract with the

plaintiff) (or) (interfered with [name of third person]’s performance of the contract, thereby

causing [name of third person] [not to perform] [to terminate] the contract with the

plaintiff);

4. The defendant’s interference with the contract was improper; and

5. The defendant’s interference with the contract caused the plaintiff (damages)

(losses).

If you find any one or more of these (number) statements has not been proved, then

your verdict must be for the defendant.

On the other hand, if you find that all of these statements have been proved, (then

your verdict must be for the plaintiff) (then you must consider the defendant’s affirmative

defense(s) of [insert any affirmative defense that would be a complete defense to the plaintiff’s

claim]).

If you find that (this affirmative defense has) (any one or more of these affirmative

defenses have) been proved by a preponderance of the evidence, then your verdict must be

for the defendant.

(In determining whether the affirmative defense of privilege [describe privilege] has

been proved, you must also determine whether the plaintiff proved by a preponderance of

the evidence that the defendant abused that privilege as explained in Instruction No. [insert

instruction number that corresponds to 24:6].)

However, if you find that (this affirmative defense has not) (none of these

affirmative defenses have) been proved, then your verdict must be for the plaintiff.