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Standard Jury Instructions - Civil

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    FORMER STANDARD JURY INSTRUCTIONS -
    CIVIL CASES

    [NOT IN EFFECT - EXCEPT FOR PRODUCTS LIABLITY]

    Individual Instructions are broken out below:

    Preliminary Sections
    THE STANDARD INSTRUCTIONS
    I
    Instructions Before and During Trial
    II
    General Instructions
    III
    Issues
    IV
    Negligence
    PL
    Product Liability
    V
    Causation
    VI
    Damages
    PD
    Punitive Damages
    MI
    Miscellaneous
    VII
    Closing Instructions
    VIII
    Verdict Forms
    Model Forms of Jury Charges
    Index

     

    Preliminary Sections






    THE STANDARD INSTRUCTIONS:


     

    I Instructions Before and During Trial

     *Currently, there are two instructions that have been erroneously numbered 1.13 at the time of adoption.  The committee has proposed that the Supreme Court renumber these instructions so that the instruction titled “jury to be guided by official English translation/interpretation” will be numbered instruction 1.13 and the instruction titled “questions by jurors” will be numbered 1.14. 



    II General Instructions





    III Issues





    IV Negligence





    PL Product Liability


    Instructions for ALL Product Liability

    • PL 1 Express warranty
    • PL 2 Implied warranty of merchantability
    • PL 3 Implied warranty of fitness for particular purpose
    • PL 4 Strict liability (manufacturing defect)
    • PL 5 Strict liability (design defect)
    • Burden of proof (greater weight of the evidence)
    • Defense issues



    V Causation





    VI Damages





    PD Punitive Damages





    MI Miscellaneous


    MI 1 Contribution Among Tortfeasors §768.31, Florida Statutes (Supp. 1976)

    MI 1 - All Instructions

    • MI 1.1 Contribution sought in independent or severed action between tortfeasors when there is no issue of reasonableness of amount paid injured party
    • MI 1.2 Contribution sought in independent action between tortfeasors when there is an issue of reasonableness of amount paid in settlement to injured person
    • MI 1.3 Contribution sought by cross-claims between defendant tortfeasors in injured party’s original action against them
    • MI 1.4 Contribution sought by third party claim in injured party’s action against third party claimant only
    • MI 1.5 Defense issue and burden of proof of intentional (willful or wanton) conduct

    MI 2 (Reserved by Committee)

    MI 3    Insurer’s Bad Faith

    MI 4   Defamation

    MI 5.1    Malicious Prosecution (Issues and Elements)

    MI 5.2    Malicious Prosecution (Damages)

    MI 6.1    False Imprisonment

    MI 7 Tortious Interference with Business Relationships

    MI 8    Fraudulent Misrepresentation; Negligent Misrepresentation (Issues & Elements)

    MI 9    Emergency Medical Treatment

    MI 10  Outrageous Conduct Causing Severe Emotional Distress

    MI 11  Civil Theft (Fla. Stat. § 772.11)

    MI 12.1   Breach of Contract Existence of Contract Admitted (terms unambiguous)

    MI 13  Claim for Personal Injury Protection Insurance Benefits (PIP) (Medical Benefits Only)




    VII Closing Instructions





    VIII Verdict Forms


    Form of Verdict Itemizing Damages Introductory Comment




    Model Forms of Jury Charges


    Model Charges Index

    Notice Concerning Use of Model Charges

    • Model Charge No. 1: automobile collision; comparative negligence; single claimant and defendant; no counterclaim; no-fault threshold issue
    • Model Charge No. 2: automobile collision; driver’s comparative negligence; failure to wear seat belt; single claimant and defendant; no counterclaim
    • Model Charge No. 3: automobile collision; comparative negligence; wrongful death damages
    • Model Charge No. 4: automobile collision; comparative negligence; claim and counter-claim
    • Model Charge No. 5: injury in 3-car collision; settlement with injured party by one tortfeasor; independent contribution claim by him against others; reasonableness of settlement as well as liability contested
    • Model Charge No. 6: claimant suing three alleged joint tortfeasors; comparative negligence in issue; contribution shares to be determined in action 36
    • Model Charge No. 7: product liability case; negligence and implied and express warranty claims; comparative negligence as defense
    • Model Charge No. 8: product liability case; negligence and strict liability claims; comparative negligence defense