Proposed Mississippi Plain Language Model Jury Instructions - Civil 2512

General Instruction

[Name of plaintiff] claims that [name of defendant 1] and [name of defendant 2]’s

negligence harmed or injured [name of plaintiff] and that [name of defendant 1] and [name of

defendant 2] are 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 concerning

each defendant:

Section A - [Name of Defendant 1]

1. [Name of defendant 1] was negligent;

2. [Name of plaintiff] suffered damages as a result of [name of defendant 1]’s negligence;

3. [Name of defendant 1]’s negligence was a substantial factor in causing [name of plaintiff]’s

damages.

Section B. - [Name of Defendant 2]

4. [Name of defendant 2] was negligent;

5. [Name of plaintiff] suffered damages as a result of [name of defendant 2]’s negligence; and

6. [Name of defendant 2]’s negligence was a substantial factor in causing [name of plaintiff]’s

damages.

Definition(s) in this Instruction:

In this instruction, “negligence” or “negligent” means doing something that a reasonably

careful [person/business/corporation] would not do under similar circumstances or failing 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:

Section A - [Name of Defendant 1]

1.Was [name of defendant 1] negligent?

YES _______ NO _______

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

here and go to Section B.

2. Did [name of plaintiff] suffer damages as a result of [name of defendant 1]’s negligence?

YES _______ NO _______

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

here and go to Section B.

3. Was [name of defendant 1]’s negligence a substantial factor in causing [name of plaintiff]’s

damages?

YES _______ NO _______

Go to Section B.

Section B - [Name of Defendant 2]

4.Was [name of defendant 2] negligent?

YES _______ NO _______

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

here and go to Section C.

5. Did [name of plaintiff] suffer damages as a result of [name of defendant 2]’s negligence?

YES _______ NO _______

If your answer to question 5 is YES, then answer question 6. If you answered NO, stop

here and go to Section C.

6. Was [name of defendant 2]’s negligence a substantial factor in causing [name of plaintiff]’s

damages?

YES _______ NO _______

Go to Section C.

Section C

7. If your answers to questions 1-3 are YES, then give a percentage of fault to

[Name of defendant 1]: [Name of defendant 1] __________%

If you answered NO to any question 1, 2, or 3, then write 0 in the blank.

If your answers to questions 4-6 are YES, then give a percentage of fault to

[Name of defendant 2]: [Name of defendant 2] __________%

If you answered NO to any question 4, 5, or 6, then write 0 in the blank.

TOTAL 100 %

8. What are [name of plaintiff]’s damages? TOTAL $__________