VA · jury_instructions
Va. Model Jury Instr. Civ. No. 39.110
Finding Instruction Common Law: Actual and Constructive Fraud
You shall return your verdict for the plaintiff if he proved by clear and convincing evidence:
(1) That the defendant misrepresented a material fact; and
(2) That the misrepresentation was made intentionally and knowingly, or it was made innocently or
negligently; and
(3) That the misrepresentation was made with the intent that the plaintiff rely upon it; and
(4) That the plaintiff relied upon it; and
(5) That the plaintiff was damaged as a result.
You shall find your verdict for the defendant if the plaintiff failed to prove any one or more of
the elements above.
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
49bc7930ad71d84f4c7dc2351fcac24c279b955fd4019716acdd9e84713fc6c4
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