Proposed Mississippi Plain Language Model Jury Instructions - Civil 2601

General Instruction

[Name of plaintiff] claims that [name of defendant] was legally negligent and that [name

of defendant] is legally responsible for [name of plaintiff]’s harm. To establish this claim, [name

of plaintiff] must prove all of the following are more likely true than not true:

1. [Name of plaintiff] and [name of defendant] had an attorney-client relationship, specifically

________________________________________ [describe the alleged attorney-client

relationship];

2. [Name of defendant] was legally negligent by ____________________________________

[describe the defendant’s alleged negligence];

3. [Name of plaintiff] suffered damages as a result of __________________________________

[describe the defendant’s alleged negligence] because [name of plaintiff]

_____________________________ [describe the result that occurred or would not have

occurred except for defendant’s legal negligence]; and

4. [Name of defendant]’s legal 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 would not do under similar circumstances or failing to do something that a

reasonably careful person would do under similar circumstances.

Verdict Form

We answer the questions submitted to us as follows:

1. Did [name of plaintiff] and [name of defendant] have an attorney-client relationship,

specifically ____________________________________ [describe the alleged attorney-client

relationship]?

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] legally negligent by ____________________________________

[describe the defendant’s alleged negligence]?

YES _______ NO _______

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

here and tell the bailiff.

3. Did [name of plaintiff] suffer damages as a result of _________________________________

[describe the defendant’s alleged negligence] because [name of plaintiff]

_____________________________ [describe the result that occurred or would not have

occurred except for defendant’s legal negligence]?

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

plaintiff]’s damages?

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

After you have filled out the verdict form, please tell the bailiff that you have reached a verdict.