CO · jury_instructions

CJI-Civ. 9:28D

Special Verdict Forms — Comparative Negligence of the Plaintiff — Single Defendant or Multiple Defendants — Designated Nonparty or Nonparties Involved — Forms A and B (Alternative to Instruction 9:28B)

activein force · 2026-02-25 – presentcompiled-edition

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. 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 plaintiff, (name): _______%

MUST TOTAL: 100%

If you determine that the negligence of the plaintiff was equal to or greater than the

combined negligence of the (defendant) (defendants) and the (nonparty) (nonparties), i.e.,

50% or more, then skip question 13.

13. 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: $_______)

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: 367c178cce06ef4cabbba30153f9ee9b43a50473001387e7f7b9425176ad94a3

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