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US-CA9 · jury_instructions

9th Cir. Model Jury Instr. (Civil) 6.2

FELA—Elements and Burden of Proof

activein force · 2026-08-20 – presentas-observed

[On the plaintiff’s [specify type of claim] claim,] the plaintiff [name] has the burden of proving both of the following elements by a preponderance of the evidence:

First, the defendant [name] was negligent; and

Second, the defendant [name]’s negligence was a cause of an injury to the plaintiff [name].

If you find that the plaintiff [name] has proved both of these elements, your verdict should be for the plaintiff [name]. If, on the other hand, the plaintiff [name] has failed to prove either of these elements, your verdict should be for the defendant [name].

The defendant [name] has the burden of proving both of the following elements by a preponderance of the evidence:

First, the plaintiff [name] was negligent; and

Second, the plaintiff [name]’s negligence was a cause of the plaintiff [name]’s own injury.

If you find that the defendant [name] has proved both of these elements, you must reduce the percentage of fault attributable to the defendant [name].

Provenance

Source
ce9.uscourts.gov
Retrieved
2026-08-20
Edition
2026-08-20
Content hash
11dfa48c84e848f87bf7d64ee11da2720593f33835cf02830d31c8c0842fe1a0
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9th Cir. Model Jury Instr. (Civil) 6.2 — FELA—Element… · binding.law