Proposed Mississippi Plain Language Model Jury Instructions - Civil 3807

Standard of Care

When two motor vehicles approach an intersection at the same time from two different

highways, the person driving the motor vehicle on the left has a duty to yield the right-of-way to

the motor vehicle on the right.

General Instruction

[Name of plaintiff] claims that [name of defendant] failed to yield the right-of-way to

[name of plaintiff] and injured [name of plaintiff]. [Name of plaintiff] claims 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. While driving their motor vehicles, both [name of plaintiff] and [name of defendant]

approached the intersection at __________ [specify the intersection] at the same time;

2. [Name of defendant] was to the left of [name of plaintiff] on __________ [specify which

highway];

3. [Name of defendant] failed to yield the right-of-way to [name of plaintiff];

4. [Name of plaintiff] suffered damages as a result of [name of defendant]’s failure to yield the

right-of-way to [name of plaintiff]; and

5. [Name of defendant]’s failure to yield the right-of-way to [name of plaintiff] was a substantial

factor in causing [name of plaintiff]’s damages.

Verdict Form

We answer the questions submitted to us as follows:

1. While driving their motor vehicles, did both [name of plaintiff] and [name of defendant]

approach the intersection at __________ [specify the intersection] at the same time?

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 [name of defendant] to the left of [name of plaintiff] on _________ [specify which

highway]?

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] fail to yield the right-of-way to [name of plaintiff]?

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 plaintiff] suffer damages as a result of [name of defendant]’s failure to yield the

right-of-way to [name of plaintiff]?

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. Was [name of defendant]’s failure to yield the right-of-way to [name of plaintiff] a substantial

factor in causing [name of plaintiff]’s damages?

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

$__________ TOTAL