Proposed Mississippi Plain Language Model Jury Instructions - Civil 2517

General Instruction

[Name of defendant] claims that [name of plaintiff]’s negligence harmed or injured [name

of defendant] and that [name of plaintiff] is legally responsible for [name of defendant]’s

damages. To establish this claim, [name of defendant] must prove all of the following are more

likely true than not true:

1. [Name of plaintiff] was negligent;

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

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

1. Was [name of plaintiff] negligent?

YES _______ NO _______

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

here with regard to this counterclaim verdict form.

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

YES _______ NO _______

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

here with regard to this counterclaim verdict form.

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

damages?

YES _______ NO _______

If your answer to question 3 is YES, then answer question 4. If you answered NO, stop

here with regard to this counterclaim verdict form.

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

$__________ TOTAL