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FL · jury_instructions

Fla. Std. Jury Instr. (Civ.) 401.23

BURDEN OF PROOF ON DEFENSE ISSUES

activein force · 2026-07-06 – presentact-effective-date

If the greater weight of the evidence does not support (defendant’s) defense[s] and the greater weight of the evidence does support (claimant’s) claim, then [your verdict should be for (claimant) in the total amount of [his] [her] damages] *[you should decide and write on the verdict form what percentage of the total negligence of [both] [all] defendants you apportion to each defendant whose negligence you find was a legal cause of loss, injury, or damage to (claimant)].

*Use second bracketed alternative above when there is more than one defendant.

If, however, the greater weight of the evidence shows that both (claimant) and [(defendant)] [one or more of (defendants)] were negligent and that the negligence of each contributed as a legal cause of [loss] [injury] [or] [damage] sustained by (claimant), you should decide and write on the verdict form what percentage of the total negligence of [both] [all] parties to this action you apportion to each of them.

Use the following instruction in cases with a comparative negligence defense and an apportionment of a non-party defense:

If, however, the greater weight of the evidence shows that (claimant) and [(defendant)] [one or more of (defendants)] and (identify additional person(s) or entit(y)(ies)) were negligent and that the negligence of each contributed as a legal cause of [loss] [injury] [or] [damage] sustained by (claimant), you should decide and write on the verdict form what percentage of the total negligence of [both] [all] parties to this action and (identify additional person(s) or entit(y)(ies)) you apportion to each of them.

Use the following instruction in cases without a comparative negligence defense but with an apportionment of a non-party defense:

If, however, the greater weight of the evidence shows that [(defendant)] [one or more of (defendants)] and (identify additional person(s) or entit(y)(ies)) were negligent and that the negligence of each contributed as a legal cause of [loss] [injury] [or] [damage] sustained by (claimant), you should decide and write on the verdict form what percentage of the total negligence of [(defendant)] and (identify additional person(s) or entit(y)(ies)) you apportion to each of them.

Provenance

Source
floridabar.org
Retrieved
2026-08-18
Edition
2026-08-18
Content hash
d5f762605bd05e49de4c5ca3e594fb332e86f4bdcd48d878751801920e661531
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