MS · jury_instructions
Proposed Mississippi Plain Language Model Jury Instructions - Civil 2515
Negligence - Comparative Negligence of Plaintiff and More than One Defendant
General Instruction
[Name of plaintiff] claims that [name of defendant 1]’s 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. [Name of defendant 1 or
2] claims that [name of plaintiff] was also negligent. To establish [name of plaintiff]’s claim,
[name of plaintiff] must prove all of the following are more likely true than not true:
Section A - [Name of plaintiff]’s Claim Against [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; and
3. [Name of defendant 1]’s negligence was a substantial factor in causing [name of plaintiff]’s
damages.
Section B - [Name of plaintiff]’s Claim Against [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.
To establish [name of defendant 1 or 2]’s claim that [name of plaintiff] was also
negligent, [name of defendant 1 or 2] must prove all of the following are more likely true than
not true:
7. [Name of plaintiff] was negligent;
8. [Name of plaintiff] suffered damages as a result of [name of plaintiff]’s negligence; and
9. [Name of plaintiff]’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 plaintiff]’s Claim Against [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 plaintiff]’s Claim Against [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, 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, 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 - [Name of defendant]’s Claim that [Name of plaintiff] Was Also Negligent
7. Was [name of plaintiff] negligent?
YES _______ NO _______
If your answer to question 7 is YES, then answer question 8. If you answered NO, go to
Section D.
8. Did [name of plaintiff] suffer damages as a result of [name of plaintiff]’s negligence?
YES _______ NO _______
If your answer to question 8 is YES, then answer question 9. If you answered NO, go to
Section D.
9. Was [name of plaintiff]’s negligence a substantial factor in causing [name of plaintiff]’s
damages?
YES _______ NO _______
Go to Section D.
Section D
10. 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.
If your answers to questions 7-9 are YES, then give a percentage of fault to
[Name of plaintiff]: [Name of plaintiff] __________%
If you answered NO to any question 7, 8, or 9, 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 2515 (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
98b0cf49bb13009dad7772c149bd8dbee78cc3c87b8c30857f394266b208181b
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