Conn. Civ. Jury Instr. 3.7-18

The plaintiff has brought this action against the defendant, (his/her) own insurance company,

under coverage known as uninsured / underinsured motorist coverage. The purpose of such

insurance is to provide compensation to the plaintiff for the damages that would have been

recoverable if the uninsured / underinsured motorist, (<defendant’s name>/the unknown driver

of the other car), had maintained an insurance policy adequate to cover the plaintiff's losses from

this incident. For this defendant to be liable to the plaintiff, the plaintiff must show that the other

driver was negligent and that the other driver’s negligence caused injury to the plaintiff.

The defendant has stipulated that the plaintiff’s insurance policy with the defendant provides this

type of coverage and that the policy was in full force and effect. You therefore do not need to

concern yourselves with the specifics of the policy.

[<If there is no stipulation on negligence:> Rather, you must determine if the plaintiff has

proved that the other driver was negligent, whether any such negligence caused injury to the

plaintiff, and if so, what amount of money will fully and fairly compensate the plaintiff. <See

Negligence - Definition, Instruction 3.6-1, Proximate Cause, Instruction 3.1-1, and Damages -

General, Instruction, 3.4-1.>]

[<If there is a stipulation on negligence:> The defendant has agreed that the other driver was

negligent and caused the accident, and thus you need not concern yourself with the question of

who caused the accident. Rather, your only task is to determine whether the plaintiff suffered

injury as a result of the accident and, if so, what amount of money will fully and fairly

compensate the plaintiff. <See Damages - General, Instruction 3.4-1.>]

[<If there is evidence of underinsurance:> You have heard testimony that the plaintiff has

already received some compensation from the other driver. You should not be concerned about

the amount, if any, that the plaintiff may have received from the other driver. If you determine

that the plaintiff was injured as a result of the negligence of the other driver, you should

determine the total amount of fair, just and reasonable compensation to which the plaintiff is

entitled, without regard to any sums the plaintiff may already have received. After you

determine the full amount to which the plaintiff is entitled, I will make any necessary

adjustments for sums the plaintiff already received.]