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Ill. Pattern Jury Instr. (Civil) 120.11

Issue/Burden Of Proof--Premises/Willful And Wanton

activein force · 2026-08-19 – presentas-observed

[In Count __], plaintiff [plaintiff's name] seeks to recover damages from the defendant

[defendant's name]. In order to recover damages, the plaintiff has the burden of proving:

First, there was a condition on the [property] [land] [building] [other] which presented an

unreasonable risk of harm to [people] [children] on the property.

Second, the defendant knew of [or] [was willful and wanton in failing to discover] both

the condition and the risk.

Third, the defendant could reasonably expect that [people] [children] on the property

would not discover or realize the danger.

Fourth, the defendant was willful and wanton in one or more of the following ways:

a) ________,

b) ________,

c) ________,

Fifth, the plaintiff was injured.

Sixth, the defendant's willful and wanton conduct was a proximate cause of the plaintiff's

injury.

Provenance

Source
illinoiscourts.gov
Retrieved
2026-08-20
Edition
2026-08-19
Content hash
ddc2a1ab2ec8b95ace52e5e8c272e82ae688a29b0d3cf2284ee9922f02106a33
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