Proposed Mississippi Plain Language Model Jury Instructions - Civil 3503

General Instruction

[Name of plaintiff] claims that [name of defendant] caused [name of plaintiff] to be

injured while on [name of defendant]’s property 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 controlled ____________ [describe business property];

2. [Name of plaintiff] went onto ____________ [describe business property] with [name of

defendant]’s express or implied permission for a purpose related to the business;

3. [A/An] ____________________ [describe dangerous condition], a dangerous condition, was

on [name of defendant]’s property;

4. [Name of defendant] knew or should have known about the dangerous condition;

5. [Name of defendant] failed to act with reasonable care to remove the dangerous condition or to

warn [name of plaintiff] about the dangerous condition;

6. [Name of plaintiff] was injured by the dangerous condition; and

7. [Name of defendant]’s failure to act with reasonable care was a substantial factor in causing

[name of plaintiff]’s damages.

Verdict Form

We answer the following questions submitted to us as follows:

1. Did [name of defendant] own or control ____________ [describe business 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] go onto ____________ [describe business property] with [name of

defendant]’s express or implied permission for a purpose related to the business?

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. Was [a/an] ____________________ [describe dangerous condition], a dangerous condition,

on [name of defendant]’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. Did [name of defendant] know or should [name of defendant] have known about the

dangerous condition?

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. Did [name of defendant] fail to act with reasonable care to remove the dangerous condition or

to warn [name of plaintiff] about the dangerous condition?

YES _______ NO ________

If your answer to question 5 is YES, then answer question 6. If you answered NO, stop

here and tell the bailiff.

6. Was [name of plaintiff] injured by the dangerous condition?

YES _______ NO ________

If your answer to question 6 is YES, then answer question 7. If you answered NO, stop

here and tell the bailiff.

7. Was [name of defendant]’s failure to act with reasonable care a substantial factor in causing

[name of plaintiff]’s damages?

YES _______ NO ________

If your answer to question 7 is YES, then answer question 8. If you answered NO, stop

here and tell the bailiff.

8. What are [name of plaintiff]’s damages?

$_________ TOTAL