CJI-Civ. 8:18

For the plaintiff, (name), to recover on (insert applicable pronoun) claim(s) of (insert

applicable theory of liability, e.g., “breach of fiduciary duty”) against the defendant, (alleged

principal’s name), you must find that all of the following have been proved by a

preponderance of the evidence:

1. The plaintiff proved (insert applicable pronoun) (insert applicable theory of liability,

e.g., “breach of fiduciary duty”) claim(s) against the defendant, (alleged agent’s name);

(2. The defendant, [alleged agent’s name], was the agent of the defendant, [alleged

principal’s name], at the time of the [insert applicable theory of liability, e.g., “breach of

fiduciary duty”] [.] [; and])

(3. The defendant, [alleged agent’s name], was acting within the scope of [insert

applicable pronoun] authority at the time of the [insert appropriate description of events, e.g.,

“occurrence,” “promise was made,” “representation was made,” etc.].)

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

then your verdict must be for the defendant, (alleged principal’s name), on the claim(s) of

(insert applicable theory of liability, e.g., “breach of fiduciary duty”).

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

proved, then your verdict must be for the plaintiff on the claim(s) of (insert applicable

theory of liability, e.g., “breach of fiduciary duty”), against the defendant, (insert alleged

principal’s name).