MS · jury_instructions

Proposed Mississippi Plain Language Model Jury Instructions - Civil 1806

Negligent Infliction of Emotional Distress - General Instruction and Verdict Form

activein force · 2012-02-17 – presentas-observed

General Instruction

[Name of plaintiff] claims that [name of defendant] was negligent and caused [him/her]

emotional distress and that [name of defendant] is legally responsible for [name of plaintiff]’s

damages. To establish this claim, [name of plaintiff] must prove all of the following are more

likely true than not true:

1. [Name of defendant] was negligent;

2. [Name of plaintiff] suffered physical harm with emotional distress;

3. [Name of defendant]’s conduct was a substantial factor in causing [name of plaintiff]’s

emotional distress; and

4. It was [expected/foreseeable/predictable] that [name of defendant]’s conduct would cause

[name of plaintiff] emotional distress.

Definition(s) in this Instruction:

In this instruction, “negligent” means that a [person/business/corporation] did something

that a reasonably careful [person/business/corporation] would not do under similar circumstances

or failed to do something that a reasonably careful [person/business/corporation] would do under

similar circumstances.

Verdict Form

We answer the questions submitted to us as follows:

1. Was [name of defendant] negligent?

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 [name of plaintiff] suffer physical harm with emotional distress?

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 [name of defendant]’s conduct a substantial factor in causing [name of plaintiff]’s

emotional distress?

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. Was it [expected/foreseeable/predictable] that [name of defendant]’s conduct would cause

[name of plaintiff] emotional distress?

YES _______ NO _______

If your answer to question 4 is YES, then answer question 5. If you answered NO, stop

here and tell the bailiff.

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

$__________ TOTAL

History

Proposed Mississippi Plain Language Model Jury Instructions - Civil 1806 (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: cf7dd074561443cf956401e2624c69f1497692b1f997928c9b12973820331da5

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