Proposed Mississippi Plain Language Model Jury Instructions - Civil 1101

General Instruction

[Name of plaintiff] claims that [name of defendant] interfered in [name of plaintiff]’s

marriage and caused an alienation of [name of spouse]’s love and affection. To establish this

claim, [name of plaintiff] must prove all of the following are more likely true than not true:

1. [Name of defendant] intentionally and wrongfully interfered in [name of plaintiff] and [name

of spouse]’s marriage by ____________________ [describe defendant’s alleged actions];

2. Because of [name of defendant]’s interference in [name of plaintiff]’s marriage, [name of

spouse] lost [his/her] love and affection for [name of plaintiff]; and

3. [Name of defendant]’s interference in [name of plaintiff]’s marriage caused harm to [name of

plaintiff].

Verdict Form

We answer the questions submitted to us as follows:

1. Did [name of defendant] intentionally and wrongfully interfere in [name of plaintiff] and

[name of spouse]’s marriage by ____________________ [describe defendant’s alleged actions]?

YES _______ NO _______

If your answer to question 1 is YES, then answer question 2. If you answered NO, stop

here and tell the bailiff.

2. Because of [name of defendant]’s interference in [name of plaintiff]’s marriage, did [name of

spouse] lose [his/her] love and affection for [name of plaintiff]?

YES _______ NO _______

If your answer to question 2 is YES, then answer question 3. If you answered NO, stop

here and tell the bailiff.

3. Did [name of defendant]’s interference in [name of plaintiff]’s marriage cause harm to [name

of plaintiff]?

YES _______ NO _______

If your answer to question 3 is YES, then answer question 4. If you answered NO, stop

here and tell the bailiff.

4. What are [name of plaintiff]’s damages?

$__________ TOTAL

After you have filled out the verdict form, please tell the bailiff that you have reached a verdict.