MS · jury_instructions
Proposed Mississippi Plain Language Model Jury Instructions - Civil 3808
Rules of the Road - Driver’s Duty to Yield to a Vehicle Driving on a Highway When Approaching from a Private Road or Driveway - General Instruction and Verdict Form
Standard of Care
When a motor vehicle is about to enter or cross a highway from a private road or
driveway, the person driving the motor vehicle has a duty to yield the right-of-way to all motor
vehicles which are driving on the highway.
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. [Name of defendant] approached __________ [specify the highway] from a private road or
driveway;
2. At that time, [name of plaintiff] was driving on __________ [specify the 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. Did [name of defendant] approach __________ [specify the highway] from a private road or
driveway?
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. At that time, was [name of plaintiff] driving on __________ [specify the 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
History
Proposed Mississippi Plain Language Model Jury Instructions - Civil 3808 (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
1eb7252542a5eb4a999d4f153754dc88d854a28ceb4753df0710c9e95e226849
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