CJI-Civ. 32:2

In determining whether the interference was intentional and so substantial that the

defendant should be required to pay the full value of (insert item of personal property), the

following factors may be considered:

1. The extent and duration of the defendant’s possession or control;

2. The defendant’s intent to assert a right inconsistent with the plaintiff’s right of

possession, control, or ownership;

3. Whether the defendant commingled the plaintiff’s (insert item of personal property)

with other property;

4. The extent and duration of the resulting interference with the plaintiff’s right of

possession, control, or ownership;

5. The harm done to (insert item of personal property); and

6. The inconvenience and expense caused to the plaintiff.

The defendant’s act or omission may be intentional even if the defendant mistakenly

believed (insert applicable pronoun)had a right to interfere with (insert item of personal

property), or was unaware of the plaintiff’s rights in (insert item of personal property).