Proposed Mississippi Plain Language Model Jury Instructions - Civil 3109

General Instruction

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

livestock] entered or trespassed onto property owned by [name of plaintiff] causing [him/her]

[damages/harm/injury]. 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 __________ [specify type of livestock];

2. [Name of defendant]’s ___________ [specify type and quantity of livestock] entered or

trespassed onto [name of plaintiff]’s property; and

3. The ____________ [specify type and quantity of livestock] trespassed onto or

[damaged/harmed/injured] [name of plaintiff]’s property.

Verdict Form

We answer the questions submitted to us as follows:

1. Did [name of defendant] own __________ [specify type of livestock]?

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]’s ___________ [specify type and quantity of livestock] enter or

trespass onto [name of plaintiff]’s property?

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 and quantity of livestock] trespass onto or

[damage/harm/injure] [name of plaintiff]’s property?

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. 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.