Proposed Mississippi Plain Language Model Jury Instructions - Civil 3105

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

domestic animal;

2. The __________ [specify type of domestic animal] had an unusually dangerous nature or

disposition;

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

4. That before the __________ [specify type of domestic animal] harmed or injured [name of

plaintiff], [name of defendant] knew or should have known that the _________ [specify the type

of domestic animal] had an unusually dangerous nature or disposition.

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. Did [name of defendant] own or keep a __________ [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 the ___________ [specify type of domestic animal] have an unusually dangerous nature or

disposition?

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 the __________ [specify type of domestic animal] harm or injure [name of plaintiff]?

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. Did [name of defendant] know or should [name of defendant] have known that the _________

[specify the type of domestic animal] had an unusually dangerous nature or disposition before the

__________ [specify type of domestic animal] harmed or injured [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. 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.