CO · jury_instructions
CJI-Civ. 9:28B
Special Verdict Forms — Comparative Negligence of the Plaintiff — Single Defendant or Multiple Defendants — Designated Nonparty or Nonparties Involved — Forms A and B
Form A:
District Court County Court Other
County, Colorado
Court Address:
[Insert Information from the original caption here - ex. In Re the
Matter of, etc.]
COURT USE ONLY
Case Number:
Division: Courtroom:
SPECIAL VERDICT FORM A
DO NOT ANSWER THIS SPECIAL VERDICT FORM A IF YOUR FOREPERSON HAS
COMPLETED SPECIAL VERDICT FORM B AND ALL JURORS HAVE SIGNED IT.
We, the jury, present our Answers to Questions submitted by the Court, to which
we have all agreed:
1. Did the plaintiff, (name), have (injuries) (damages) (losses)? (Yes or No)
ANSWER: _______
2. Was the defendant, (name of first or only defendant), negligent? (Yes or No)
ANSWER: _______
3. Was the negligence, if any, of the defendant, (name of first or only defendant), a
cause of any of the (injuries) (damages) (losses) claimed by the plaintiff? (Yes or No)
ANSWER: _______
(4. Was the defendant, [name of second defendant], negligent? [Yes or No]
ANSWER: _______)
(5. Was the negligence, if any, of the defendant, [name of second defendant], a cause
of any of the [injuries] [damages] [losses] claimed by the plaintiff? [Yes or No]
ANSWER: _______)
We, the jury, find for the defendant(s) and award no damages to the plaintiff,
(name).
Signatures of all jurors:
______________________________ ______________________________
Foreperson
______________________________ ______________________________
______________________________ ______________________________
Form B:
District Court County Court Other
County, Colorado
Court Address:
[Insert Information from the original caption here - ex. In Re the
Matter of, etc.]
COURT USE ONLY
Case Number:
Division: Courtroom:
SPECIAL VERDICT FORM B
DO NOT ANSWER THIS SPECIAL VERDICT FORM B IF YOUR FOREPERSON HAS
COMPLETED SPECIAL VERDICT FORM A AND ALL JURORS HAVE SIGNED IT.
We, the jury, present our Answers to Questions submitted by the Court, to which
we have all agreed:
1. Did the plaintiff, (name), have (injuries) (damages) (losses)? (Yes or No)
ANSWER: _______
2. Was the defendant, (name of first or only defendant), negligent? (Yes or No)
ANSWER: _______
3. Was the negligence, if any, of the defendant, (name of first or only defendant), a
cause of any of the (injuries) (damages) (losses) claimed by the plaintiff? (Yes or No)
ANSWER: _______
(4. Was the defendant, [name of second defendant], negligent? [Yes or No]
ANSWER: _______)
(5. Was the negligence, if any, of the defendant, [name of second defendant], a cause
of any of the [injuries] [damages] [losses] claimed by the plaintiff? [Yes or No]
ANSWER: _______)
If you find that the plaintiff did have (injuries) (damages) (losses), and you further
find that (the defendant) (one or more of the defendants) was negligent and that such
negligence was a cause of any of the plaintiff’s (injuries) (damages) (losses), then answer
the following questions:
6. Was (name or other appropriate description of first or only designated nonparty)
negligent? (Yes or No)
ANSWER: _______
7. Was the negligence, if any, of (name or other appropriate description of first or only
designated nonparty) a cause of any of the (injuries) (damages) (losses) claimed by the
plaintiff? (Yes or No)
ANSWER: _______
(8. Was [name or other appropriate description of second designated nonparty]
negligent? [Yes or No]
ANSWER: _______)
(9. Was the negligence, if any, of [name or other appropriate description of second
designated nonparty] a cause of any of the [injuries)] [damages] [losses] claimed by the
plaintiff? [Yes or No]
ANSWER: _______)
10. Was the plaintiff, (name), negligent? (Yes or No)
ANSWER: _______
11. Was the negligence, if any, of the plaintiff a cause of (insert applicable pronoun)
own claimed (injuries) (damages) (losses)? (Yes or No)
ANSWER: _______
12. State your answers to the following questions relating to the plaintiff’s damages
that were caused by the negligence, if any, of the parties to this lawsuit and the negligence,
if any of the (nonparty) (nonparties), (name or names or other appropriate description):
a. What is the total amount of the plaintiff’s damages, if any, for noneconomic losses
or injuries (, excluding any damages for [physical impairment] [or]
[disfigurement])? Noneconomic losses or injuries are those losses or injuries
described in numbered paragraph 1 of Instruction (insert number of the applicable
Instruction on damages). You should answer “0” if you determine there were none.
ANSWER: $_______
b. What is the total amount of the plaintiff’s damages, if any, for economic losses (,
excluding any damages for [physical impairment] [or] [disfigurement])? Economic
losses are those losses described in numbered paragraph 2 of Instruction (insert
number of applicable Instruction on damages). You should answer “0” if you
determine there were none.
ANSWER: $_______
(c. What is the total amount of the plaintiff’s damages, if any, for [physical
impairment] [or] [disfigurement]? You should answer “0” if you determine there
were none.)
ANSWER: $_______
13. Taking as 100 percent the combined negligence of all parties and (any nonparty)
you find were negligent and whose negligence was a cause of any of the plaintiff’s (injuries)
(damages) (losses), what percentage of negligence, if any, was that of the defendant, (name
of first or only defendant), (of the defendant, [name of second defendant],) (of the nonparty,
[name or other appropriate description of first or only nonparty]), (of the nonparty, [name or
other appropriate description of second nonparty]) and of the plaintiff, (name)? Enter the
figure zero, “0,” for any party or nonparty you decide was not negligent or whose
negligence you decide was not a cause of any of the plaintiff’s claimed (injuries) (damages)
(losses).
ANSWER:
Percentage charged to (name of first or only defendant): _______%
Percentage charged to (name of second defendant):
_______%
Percentage charged to (name of first or only nonparty): _______%
Percentage charged to (name of second nonparty):
_______%
Percentage charged to plaintiff, (name): _______%
MUST TOTAL: 100%
Signatures of all jurors:
______________________________ ______________________________
Foreperson
______________________________ ______________________________
______________________________ ______________________________
History
CJI-Civ. (2026), Colorado Supreme Court Committee on Pattern Civil Jury Instructions. Dated 2026-02-25 by the committee page's "Revised 2/25/26".
Provenance
- Source
- www.coloradojudicial.gov
- Retrieved
- 2026-09-24
- Edition
- civ-2026-02-25
- Content hash
fd9cd7adc695f892c6daa55a4a22fd1107cd6069b8fe54ce801f1c3259da9118
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