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US-CA11 · jury_instructions

11th Cir. Pattern Jury Instr. (Civil) 4.23

Miscellaneous Issues – Constructive Discharge

activein force · 2025-12-01 – presentact-effective-date

In this case, [name of plaintiff] claims that [he/she] lost wages and benefits

because [name of defendant] “constructively discharged” [name of plaintiff] from

[his/her] job. Put another way, [name of plaintiff] claims that [he/she] left [his/her]

job because the hostile work environment made [his/her] working conditions

intolerable.

[Name of defendant] denies that [he/she/it] constructively discharged [name

of plaintiff] and claims that [name of plaintiff] voluntarily quit.

To prove constructive discharge, [name of plaintiff] must prove that the

hostile work environment made [his/her] working conditions so intolerable that a

reasonable person in [his/her] position would have felt compelled to resign.

If you find that [name of defendant] constructively discharged [name of

plaintiff], you may award [name of plaintiff] lost wages and benefits caused by the

constructive discharge. If you find that [name of plaintiff] was not constructively

discharged, you may not award [name of plaintiff] lost wages and benefits due to

the loss of employment.

Provenance

Source
ca11.uscourts.gov
Retrieved
2026-08-20
Edition
civil-2025-12
Content hash
e8603eb573a974b898da3d58a1b122c9d19023047efdb6210499b2a4861a01c1
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