VA · jury_instructions
Va. Model Jury Instr. Civ. No. 33.000
Negligent Infliction of Emotional Distress: Issues
Your verdict must be based on the facts as you find them and on the law contained in all of
these instructions.
The issues in this case are:
(1) Was the defendant negligent;
(2) Was the defendant’s negligence a proximate cause of any [emotional distress; fright; shock] that
naturally resulted in a physical injury to the plaintiff; and
(3) Did the plaintiff suffer damages as a result of the defendant’s act?
On issue (1), the plaintiff has the burden of proof by the greater weight of the evidence. On
issues (2) and (3), the plaintiff has the burden of proof by clear and convincing evidence.
Your decisions on these issues must be governed by the instructions that follow.
History
Virginia Model Jury Instructions – Civil, Release 26, April 2026. The unannotated set, posted by the Supreme Court of Virginia at vacourts.gov; the book states that it is made available with the permission of the publisher, Matthew Bender & Company, Inc.
Provenance
- Source
- vacourts.gov
- Retrieved
- 2026-10-11
- Edition
- civ-2026-04-01
- Content hash
b30f012cf99e50d7ae7a398428c1175013fe8b5a05c7a7da062e16a2cb638b56
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