Ill. Pattern Jury Instr. (Civil) 255.12

INSTRUCTION

As to plaintiff ’s claim of harassment [in Count . . . of the Complaint], the plaintiff must

prove each of the following propositions by a preponderance of the evidence:

a) The defendant [the defendant ’s employee/s] [briefly describe the unwelcome conduct on

the basis of the plaintiff ’s actual or perceived race, color, religion, national origin, ancestry, age,

sex, marital status, order of protection status, disability, military status, sexual orientation,

pregnancy, unfavorable discharge from military service, or citizenship status];

b) The conduct was sufficiently severe or pervasive that a reasonable person in plaintiff ’s

position would find plaintiff’s work environment to be hostile or abusive;

c) At the time the conduct occurred, plaintiff believed that the conduct made his/her work

environment hostile or abusive;

d) [for cases where the plaintiff alleges a claim against a defendant employer based on the

conduct of a nonemployee or a nonmanagerial or nonsupervisory employee: The d efendant

became aware of the conduct and failed to take reasonable corrective measures]; and

e) The plaintiff sustained damages because of the defendant’s conduct.

If you find from your consideration of all the evidence that each of these propositions has

been proved, then your verdict will be for the plaintiff and you should proceed to Verdict Form . .

. .

On the other hand, if you find from your consideration of all the evidence that any of these

propositions has not been proved, then your verdict will be for the defendant and you should

proceed to Verdict Form . . . .

Instruction, Notes on Use and Comment approved December 2022.