Wis JI-Civil 1750.2

[NOTE: The Committee believes use of this unsubdivided

special verdict will be limited. See Comment.]

Question _____ asks what sum of money will fairly and reasonably compensate

(plaintiff) for any personal injuries (he) (she) sustained as a result of the accident. Your

answer to this question should be the amount of money that will fairly and reasonably

compensate (plaintiff) for the personal injuries (he) (she) has suffered to date and is

reasonably certain to suffer in the future as a result of the accident.

Personal injuries include pain, suffering, and disability (disfigurement) which means

any physical pain, worry, distress, embarrassment and humiliation which (plaintiff) has

suffered in the past and is reasonably certain to suffer in the future. You should consider also

to what extent (his) (her) injuries have impaired and will impair (his) (her) ability to enjoy the

normal activities, pleasures, and benefits of life. Consider the nature of (plaintiff)'s injuries,

the effect produced by (plaintiff)'s injuries in the past, and the effect the injuries are

reasonably certain to produce in the future, bearing in mind (plaintiff)'s age, prior mental and

physical condition, and the probable duration of (his) (her) life.

Personal injuries can also include any loss of future earning capacity suffered by

(plaintiff). If you are satisfied that (plaintiff) has suffered a loss of future earning capacity as

a result of the injuries sustained in the accident, your answer to this question should include

the difference between what (plaintiff) will reasonably be able to earn in the future in view of

the injuries sustained and what (he) (she) would have been able to earn had (he) (she) not

been injured.

[Where appropriate add the following paragraph: Because (plaintiff) was the

owner and operator of a business at the time of the accident, you should, in determining (his)

(her) loss of future earning capacity, consider the character and size of the business, the

capital and labor employed in the business, (and) the extent and quality of (plaintiff)'s

services to the business, (and the profits of the business).]

Personal injuries can also include health care and treatment expenses. If you are

satisfied that (plaintiff) will require health care and treatment in the future for injuries

sustained as a result of the accident, include in your answer to this question the sum of money

that will reasonably and necessarily be expended in the future for that care and treatment.