Proposed Mississippi Plain Language Model Jury Instructions - Civil 3514

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 property]; and

2. [Name of plaintiff] went onto ____________ [describe property] without [name of

defendant]’s permission;

3. [Name of defendant] intentionally or with ill will injured [name of plaintiff] by

________________________ [describe defendant’s alleged actions]; and

4. [Name of defendant]’s [act/acts] [was/were] a substantial factor in causing [name of

plaintiff]’s damages.

Verdict Form

We answer the questions submitted to us as follows:

1. Did [name of defendant] own or control ____________ [describe 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 property] without [name of

defendant]’s permission?

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] intentionally or with ill will injure [name of plaintiff] by

________________________ [describe defendant’s alleged actions]?

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. [Was/Were] [name of defendant]’s act(s) a substantial factor in causing [name of plaintiff]’s

damages?

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