Proposed Mississippi Plain Language Model Jury Instructions - Civil 5015

You are to decide what wrongful death damages to award the plaintiff. You may consider

the following factors in determining the amount of wrongful death damages to award the

plaintiff:

A. Every Kind of Damages Suffered by the Deceased Person As a Result of His or Her

Death

1. The amount of money that the deceased person would have earned over [his/her] work-life

expectancy had [he/she] not been injured;

2. The reasonable and necessary medical expenses for treating the deceased person after the

[accident/injury] which led to [his/her] death;

3. The deceased person’s physical pain and mental suffering from the date of the

[accident/injury] which led to [his/her] death until [his/her] death;

4. The reasonable and necessary burial and funeral expenses for the deceased person’s funeral;

5. The reasonable expenses for property damage suffered by the deceased person as result of the

[accident/injury] which led to [his/her] death; and

6. The reasonable cost of administering the deceased person’s estate.

B. Every Kind of Damages Suffered by All of the Parties to the Wrongful Death Claim

By the Deceased Person’s Spouse and/or Children

1. The spouse’s loss of love, affection, companionship, and services as a result of [his/her] death;

2. Each child’s loss of training and guidance by [his/her] [father/mother] from the date of the

deceased person’s death; and

3. Each child’s loss of love and companionship with [his/her] [father/mother] from the date of

the deceased person’s death.

By the Deceased Person’s Parents and/or Brothers and Sisters

1. The father and mother’s loss of love and companionship with [his/her/their] child from the

date of the deceased person’s death; and/or

2. Each brother’s and each sister’s loss of love and companionship with [his/her] [brother/sister]

from the date of the deceased person’s death.