Proposed Mississippi Plain Language Model Jury Instructions - Civil 1901

General Instruction

[Name of plaintiff] claims that [name of defendant] invaded [name of plaintiff]’s privacy

by intruding on [his/her] privacy or seclusion. To establish this claim, [name of plaintiff] must

prove all of the following are more likely true than not true:

1. [Name of plaintiff] had a right to privacy or seclusion in ___________________ [describe

location or circumstance];

2. [Name of defendant] intentionally intruded on [name of plaintiff]’s privacy or seclusion by

____________________ [describe defendant’s alleged actions];

3. [Name of defendant]’s intrusion was highly offensive to a reasonable person; and

4. [Name of defendant]’s intrusion caused harm to [name of plaintiff].

Verdict Form

We answer the questions submitted to us as follows:

1. Did [name of plaintiff] have a right to privacy or seclusion in ___________________

[describe location or circumstance]?

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 defendant] intentionally intrude on [name of plaintiff]’s privacy or seclusion by

____________________ [describe defendant’s alleged actions]?

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 intrusion highly offensive to a reasonable person?

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. Did [name of defendant]’s intrusion cause harm to [name of plaintiff]?

YES _______ NO _______

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

here and tell the bailiff.

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

$__________ TOTAL