MS · jury_instructions
Proposed Mississippi Plain Language Model Jury Instructions - Civil 3210
Bailment - Mutual Benefit - Bailee’s Alleged Failure to Follow the Standard of Care
General Instruction
[Name of plaintiff bailor] claims that [name of defendant bailee] damaged or harmed
[a/an/the] _______________ [specify property] and that [name of defendant bailee] is legally
responsible for that damage or harm. To establish this claim, [name of plaintiff bailor] must
prove all of the following are more likely true than not true:
1. [Name of plaintiff bailor] gave [a/an/the] _______________ [specify property] to [name of
defendant bailee];
2. The bailment of the _______________ [specify property] was for the benefit of both [name of
plaintiff bailor] and [name of defendant bailee];
3. [Name of defendant bailee] did not take reasonable care of the _______________ [specify
property]; and
4. [Name of defendant bailee]’s failure to take reasonable care of the _____________ [specify
property] was a substantial factor in causing damage or harm to the ____________ [specify
property].
Verdict Form
We answer the questions submitted to us as follows:
1. Did [name of plaintiff bailor] give [a/an/the] _____________ [specify property] to [name of
defendant bailee]?
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 the bailment of the ___________ [specify property] for the benefit of both [name of
plaintiff bailor] and [name of defendant bailee]?
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 bailee] take reasonable care of the___________ [specify property]?
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. Was [name of defendant bailee]’s failure to take reasonable care of the ____________ [specify
property] a substantial factor in causing damage or harm to the _____________ [specify
property]?
YES _______ NO ________
If your answers to questions 1, 2, and 4 are YES and your answer to question 3 is NO,
then answer question 5. If you answered NO to question 4, stop here and tell the bailiff.
5. What are [name of plaintiff bailor]’s damages?
$__________ TOTAL
After you have filled out the verdict form, please tell the bailiff that you have reached a verdict.
History
Proposed Mississippi Plain Language Model Jury Instructions - Civil 3210 (current as of February 17, 2012). Submitted in 2012 by the Mississippi Model Jury Instructions Commission (created by the Supreme Court of Mississippi by order of December 30, 2008) and published by the Court on courts.ms.gov. The Court states that these model jury instructions have not been adopted or approved by the Supreme Court of Mississippi.
Provenance
- Source
- courts.ms.gov
- Retrieved
- 2026-09-25
- Edition
- 2026-09-25
- Content hash
2816d12694411bbb9e7e4c818fdc4f22c7649d36b62e78a70f0dc16dd9f611d4
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