CJI-Civ. 8:24

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

appropriate theories of liability, e.g., “negligence”) against the defendant, (alleged employer’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., “negligence”) claim(s);

(2. [Alleged employee’s name], was the employee of the defendant, [alleged employer’s

name], at the time of the [insert appropriate description of events, e.g., “occurrence,”

“collision,” “accident,” etc.] [.] [; and])

(3. [Alleged employee’s name] was acting within the scope of [insert applicable

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

“occurrence,” “collision,” “accident,” 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 employer’s name), on the claim(s) of

(insert applicable theory of liability, e.g., “negligence”).

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., “negligence”), against the defendant, (insert alleged employer’s name).