Proposed Mississippi Plain Language Model Jury Instructions - Civil 3304

General Instruction

[Name of plaintiff] claims that [name of defendant] damaged or lost [his/her]

___________ [describe plaintiff’s property] and that [name of defendant] is legally responsible

for that damage or loss. To establish this claim, [name of plaintiff] must prove all of the

following are more likely true than not true:

1. [Name of defendant] was a common carrier of property;

2. [Name of plaintiff] delivered _____________ [describe plaintiff’s property] to [name of

defendant] for shipment; and

3A. [Name of plaintiff]’s _____________ [describe plaintiff’s property] was damaged or lost

while being carried or transported by [name of defendant];

OR

3B. [Name of plaintiff]’s _____________ [describe plaintiff’s property] was damaged or lost

after its arrival at _________________ [describe the location where the property was allegedly

damaged or lost] before [name of plaintiff] was notified of its arrival and before [name of

plaintiff] had a reasonable opportunity to pick up the _____________ [describe plaintiff’s

property].

Verdict Form

We answer the questions submitted to us as follows:

1. Was [name of defendant] a common carrier of property?

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 plaintiff] deliver the _____________ [describe plaintiff’s property] to [name of

defendant] for shipment?

YES _______ NO ________

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

here and tell the bailiff.

3A. Was [name of plaintiff]’s _____________ [describe plaintiff’s property] damaged or lost

while being carried or transported by [name of defendant]?

OR

3B. Was [name of plaintiff]’s _____________ [describe plaintiff’s property] damaged or lost

after its arrival at ____________ [describe the location where the property was allegedly

damaged or lost] before [name of plaintiff] was notified of its arrival and before [name of

plaintiff] had a reasonable opportunity to pick up the _____________ [describe 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