Ill. Pattern Jury Instr. (Civil) 150.09

Intoxicated Person--Tavern Operator and Property Owner Both Sued

[In this lawsuit] [In Count ,] plaintiff [(name)] claims [(name)] is entitled to recover

damages from the defendant. The plaintiff must prove:

First, [(name of intoxicated person)] was int ox icated at the time of the [( e.g ., collision)].

Second, the defendant [(tavern op erator)], or his ag ents or se rvants, sold or gave

intoxicating liquors consumed by [(name of intoxicated person)].

Third, the liquor thus consumed caused the intoxication of [(name of intoxi cated

person)].

Fourth, [(intox i cated pe rson)] intoxication was at least one cause of the occurrence in

question.

Fifth, as a re sult of the occurrence, plaintiff suffered [injury] [damage to his property].

In the case against the defendant [name of propert y owner], the plaintiff has the

burden of proving all the foregoing propositions and also must prove the further proposition

that the defendant [name of property owner] [either] [owned], [rented], [lease d] [or] [permitted

the occupa tion of] the premises [knowing that alcoholic liquors we re to be sold there] [or]

[although (owning ), (r enting), (leasing) (or) (pe rmitting the occupation of) the premises for

purposes other than selling alcoholic liquors, knowingly permitted them to be sold there].