Proposed Mississippi Plain Language Model Jury Instructions - Civil 3103

General Instruction

[Name of plaintiff] claims that [name of defendant]’s __________ [specify type of

domestic animal] harmed or injured [him/her] and that [name of defendant] is 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:

1. [A/An] ___________ [specify type of domestic animal] is a domestic animal;

2. [Name of defendant] owned or kept a __________ [specify type of domestic animal], which

was not an abnormally dangerous animal;

3. [Name of defendant] did not take reasonable steps under the circumstances to control the

__________ [specify type of domestic animal];

4. The __________ [specify type of domestic animal] harmed or injured [name of plaintiff]; and

5. [Name of defendant]’s failure to take reasonable steps under the circumstances to control the

_________ [specify type of domestic animal] was a substantial factor in causing [name of

plaintiff]’s damages.

Definition(s) in this Instruction:

In this instruction, “domestic animal” means an animal that is customarily owned or used

by people.

Verdict Form

We answer the questions submitted to us as follows:

1. Is [a/an] ___________ [specify type of domestic animal] a domestic animal?

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. Did [name of defendant] own or keep a __________ [specify type of domestic animal], which

was not an abnormally dangerous animal?

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 defendant] take reasonable steps under the circumstances to control the

__________ [specify type of domestic animal]?

YES _______ NO _______

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

here and tell the bailiff.

4. Did the ____________ [specify type of domestic animal] harm or injure [name of plaintiff]?

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. Was [name of defendant]’s failure to take reasonable steps under the circumstances to control

the _________ [specify type of domestic animal] a substantial factor in causing [name of

plaintiff]’s damages?

YES _______ NO _______

If your answers to questions 1, 2, 4, and 5 are YES and your answer to question 3 is NO,

then answer question 6. If you answered NO to question 5, stop here and tell the bailiff.

6. 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.