Proposed Mississippi Plain Language Model Jury Instructions - Civil 3811

General Instruction

[Name of plaintiff] claims that [name of defendant minor driver] was negligent while

driving a motor vehicle and injured [name of plaintiff]. [Name of plaintiff] claims that [name of

defendant parent or guardian] 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. On or about __________ [specify date application was signed], [name of defendant parent or

guardian] signed [name of defendant minor driver]’s application for a driver’s permit or license;

2. On or about __________ [specify date of defendant minor driver’s alleged conduct],

[name of defendant minor driver] was negligent by _______________________ [describe

defendant minor driver’s alleged actions] on __________ [specify the highway]; and

3. When [name of defendant minor driver] was negligent by _______________________

[describe defendant minor driver’s alleged actions] on __________ [specify the highway],

[name of defendant minor driver] was:

A. Less than 17 years old; and

B. Driving under the authority of a driver’s permit or license; and

4. [Name of plaintiff] suffered damages as a result of [name of defendant minor driver]’s

negligence; and

5. [Name of defendant minor driver]’s negligence was a substantial factor in causing [name of

plaintiff]’s damages.

Definition(s) in this Instruction:

In this instruction, “negligence” or “negligent” means doing something that a reasonably

careful [person/business/corporation] would not do under similar circumstances or failing to do

something that a reasonably careful [person/business/corporation] would do under similar

circumstances.

Verdict Form

We answer the questions submitted to us as follows:

1. On or about __________ [specify date application was signed], did [name of defendant parent

or guardian] sign [name of defendant minor driver]’s application for a driver’s permit or license?

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. On or about __________ [specify date of defendant minor driver’s alleged conduct], was

[name of defendant minor driver] negligent by _______________________ [describe defendant

minor driver’s alleged actions] 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. When [name of defendant minor driver] was negligent by _______________________

[describe defendant minor driver’s actions] on __________ [specify highway], was [defendant

minor driver]:

A. Less than 17 years old; and

B. Driving under the authority of a driver’s permit or license?

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 minor driver]’s

negligence?

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 minor driver]’s negligence 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