Proposed Mississippi Plain Language Model Jury Instructions - Civil 719

[Name of plaintiff] claims that [name of defendant] intentionally interfered with a

contract between [name of plaintiff] and [name of other contracting party] 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 plaintiff] and [name of other contracting party] entered into a valid and enforceable

contract to _____________________ [describe the subject matter of the contract];

2. [Name of defendant] knew or should have known about the contract;

3. [Name of defendant] intentionally and harmfully acted with no justification or excuse to

interfere with [name of other contracting party]’s performance of the contract by

_____________________________ [describe the defendant’s actions to allegedly interfere];

4A. [Name of defendant]’s interference prevented [name of other contracting party]’s

performance of the contract;

OR

4B. [Name of defendant]’s interference caused [name of other contracting party] to breach the

contract; and

5. [Name of other contracting party] would have performed the contract if not for [name of

defendant]’s intentional interference;

6. [Name of plaintiff] suffered damages as a result of [name of other contracting party]’s failure

to perform or breach of the contract; and

7. [Name of defendant]’s intentional inference with the contract 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 plaintiff] and [name of other contracting party] enter into a valid and enforceable

contract to _____________________ [describe the subject matter of the contract]?

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 defendant] know or should [name of defendant] have known about the contract?

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 and harmfully act with no justification or excuse to

interfere with [name of other contracting party]’s performance of the contract by

_____________________________ [describe the defendant’s actions to allegedly interfere]?

YES _______ NO ________

If your answer to question 3 is YES, then answer question 4. If you answered NO, stop

here and tell the bailiff.

4A. Did [name of defendant]’s interference prevent [name of other contracting party]’s

performance of the contract?

OR

4B. Did [name of defendant]’s interference cause [name of other contracting party] to breach the

contract?

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. Would [name of other contracting party] have performed the contract if not for [name of

defendant]’s intentional interference?

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. Did [name of plaintiff] suffer damages as a result of [name of other contracting party]’s failure

to perform or breach of the contract?

YES _______ NO ________

If your answer to question 6 is YES, then answer question 7. If you answered NO, stop

here and tell the bailiff.

7. Was [name of defendant]’s intentional inference with the contract a substantial factor in

causing [name of plaintiff]’s damages?

YES _______ NO ________

If your answer to question 7 is YES, then answer question 8. If you answered NO, stop

here and tell the bailiff.

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

$_________ TOTAL

After you have filled out the verdict form, please tell the bailiff that you have reached a verdict.