MS · jury_instructions
Proposed Mississippi Plain Language Model Jury Instructions - Civil 1403
Defamation Per Se - General Instruction and Verdict Form
General Instruction
[Name of plaintiff] claims that [name of defendant] harmed [him/her/it] by
[saying/writing] a statement of fact that was false and that [name of defendant] is legally
responsible for that harm. To establish this claim, [name of plaintiff] must prove all of the
following are more likely true than not true:
1. [Name of defendant] [said/wrote] ___________________________________ [describe the
allegedly defamatory statement], or similar words, to [name of third party to whom the
statements were made]; and
2. The statement accused [name of plaintiff] of ____________________________________
[specify (1) committing a serious crime; (2) having an awful or contagious disease; (3) being
sexually active or not being a virgin; or (4) doing something that would harm [name of
plaintiff]’s business, job, or profession]; and
3. The statement was false.
Verdict Form
We answer the questions submitted to us as follows:
1. Did [name of defendant] [say/write] ___________________________ [describe the allegedly
defamatory statement], or similar words, to [name of third party to whom the statements were
made]?
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. Did the statement accuse [name of plaintiff] of ____________________________________
[specify (1) committing a serious crime; (2) having an awful or contagious disease; (3) being
sexually active or not being a virgin; or (4) doing something that would harm [name of
plaintiff]’s business, job, or profession]?
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. Was the statement false?
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.
History
Proposed Mississippi Plain Language Model Jury Instructions - Civil 1403 (current as of February 17, 2012). Submitted in 2012 by the Mississippi Model Jury Instructions Commission (created by the Supreme Court of Mississippi by order of December 30, 2008) and published by the Court on courts.ms.gov. The Court states that these model jury instructions have not been adopted or approved by the Supreme Court of Mississippi.
Provenance
- Source
- courts.ms.gov
- Retrieved
- 2026-09-25
- Edition
- 2026-09-25
- Content hash
a88e1dcd92314e0933d71df32082ad888094b2e4eb53f79575ff04c9ee12f155
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