Proposed Mississippi Plain Language Model Jury Instructions - Civil 1904

General Instruction

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

by publicly [placing/representing] [name of plaintiff] in a false [light/way]. 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 publicly [placed/represented] [name of plaintiff] in a

false [light/way] by ____________________ [describe defendant’s alleged actions];

2. [Name of defendant]’s [placement/representation] of [name of plaintiff] in a false [light/way]

was highly offensive to a reasonable person;

3A. [Name of defendant] knew that what [he/she/it] [said/wrote/disclosed] about [name of

plaintiff] was false and that it would [place/represent] [name of plaintiff] in a false [light/way];

OR

3B. [Name of defendant] acted with reckless disregard about whether what [he/she/it]

[said/wrote/disclosed] about [name of plaintiff] was false and that it would [place/represent]

[name of plaintiff] in a false [light/way]; and

4. [Name of defendant]’s [placing/representing] [name of plaintiff] in a false [light/way] caused

harm to [name of plaintiff].

Definition(s) in this Instruction:

In this instruction, “reckless” disregard means a person knows that a risk of emotional

distress would probably result from [his/her] conduct and then disregards that risk and the harm

that may occur as a result.

Verdict Form

We answer the questions submitted to us as follows:

1. Did [name of defendant] intentionally and publicly [place/represent] [name of plaintiff] in a

false [light/way] 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. Was [name of defendant]’s [placement/representation] of [name of plaintiff] in a false

[light/way] highly offensive to a reasonable person?

YES _______ NO _______

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

here and tell the bailiff.

3A. Did [name of defendant] know that what [he/she/it] [said/wrote/disclosed] about [name of

plaintiff] was false and that it would [place/represent] [name of plaintiff] in a false [light/way]?

OR

3B. Did [name of defendant] act with reckless disregard about whether what [he/she/it]

[said/wrote/disclosed] about [name of plaintiff] was false and that it would [place/represent]

[name of plaintiff] in a false [light/way]?

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 [placing/representing] [name of plaintiff] in a false [light/way]

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.

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

$__________ TOTAL