MS · jury_instructions
Proposed Mississippi Plain Language Model Jury Instructions - Civil 2513
Negligence - Negligence by One Defendant and One Non-Party - General Instruction and Verdict Form
General Instruction
[Name of plaintiff] claims that [name of defendant] and [name of non-party]’s negligence
harmed or injured [name of plaintiff] and that [name of defendant 1] and [name of non-party] 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:
Section A - [Name of Defendant]
1. [Name of defendant] was negligent;
2. [Name of plaintiff] suffered damages as a result of [name of defendant]’s negligence;
3. [Name of defendant]’s negligence was a substantial factor in causing [name of plaintiff]’s
damages.
Section B - [Name of Non-Party]
4. [Name of non-party] was negligent;
5. [Name of plaintiff] suffered damages as a result of [name of non-party]’s negligence; and
6. [Name of non-party]’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.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 go to Section B.
2. Did [name of plaintiff] suffer damages as a result of [name of defendant]’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]’s negligence a substantial factor in causing [name of plaintiff]’s
damages?
YES _______ NO _______
Go to Section B.
Section B - [Name of Non-Party]
4.Was [name of non-party] 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 non-party]’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 non-party]’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]: [Name of defendant] __________%
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 non-party]: [Name of non-party] __________%
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 $__________
History
Proposed Mississippi Plain Language Model Jury Instructions - Civil 2513 (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
1d75bd5177d78e3090aca2d79ea35089aae2ef78e90038b38ad6d96932411a33
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