Ill. Pattern Jury Instr. (Civil) 255.15

Plaintiff claims that defendant[s] retaliated against plaintiff because plaintiff [describe

plaintiff’s protected activity]. To succeed on this claim, plaintiff must prove by a preponderance

of the evidence the following:

1. That plaintiff had a reasonable and good faith belief that plaintiff had been

[discriminated against and/or harassed];

2. That plaintiff [engaged in protected activity];

3. That defendant[s] [describe action adverse to plaintiff];

4. That defendant’s action [describe the action adverse to plaintiff] was materially adverse

to plaintiff;

5. The defendant[s] took the materially adverse action because plaintiff [engaged in

protected activity];

6. That, because of the materially adverse action, plaintiff sustained damages.

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

been proven, then your verdict should be for plaintiff. On the other hand, if you find from your

consideration of all the evidence that any of these propositions has not been proven, then your

verdict should be for defendant.

Instruction and Notes on Use approved December 2022.