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name: jury-instructions language: en description: Drafts complete proposed jury instruction sets for U.S. litigation, including preliminary charges, elements, burden of proof, evidence evaluation, and verdict forms. Adapts to jurisdiction-specific pattern instructions. Use when drafting jury instructions, jury charges, verdict forms, or special interrogatories during trial preparation.

Jury Instructions

Drafts proposed jury instructions tailored to case, jurisdiction, and claims at issue.

Prerequisites

Gather before drafting:

• Pleadings/pretrial order — complaint, answer, counterclaims, stipulated facts, MIL rulings
• Jurisdiction — state/federal, specific court, applicable pattern instructions
• Claims and defenses — all causes of action, affirmative defenses, statutory/common-law basis
• Verdict form type — general, special, or interrogatories
• Key evidence — expert witnesses, exhibits, stipulations

Instruction Sequence

Draft in this order using numbered paragraphs with descriptive headings.

1. Preliminary Instructions

Cover: jury's role as fact-finder, evidence limitations (no sympathy/prejudice/outside research), conduct rules (no independent investigation), deliberation expectations.

• Pull jurisdiction's standard preliminary pattern instructions
• Adapt to case type (civil/criminal)

2. Case Statement

• Neutral, non-argumentative summary from undisputed facts, pleadings, and stipulations only
• Identify parties by name and role; state dispute nature and chronology
• Never use characterizations favorable to either side

3. Legal Definitions

• Define every legal term before it appears in elements instructions
• Source hierarchy: (1) statutory definitions → (2) pattern instructions → (3) controlling case law
• Build progressively — foundational terms first, compound concepts second

4. Elements Instructions

For each claim/charge/defense:

1. Number every element
2. Identify burden-bearing party per element
3. Explain each element in case-specific context
4. Address circumstantial-evidence inferences for mental-state elements
5. Make contingent-claim sequencing explicit

• Cite controlling statute or case law per element
• Cross-reference pattern instructions
• Flag affirmative defenses and burden-shifting

5. Burden of Proof

Standard	Context	Core Language
Preponderance	Most civil claims	More likely true than not
Clear and convincing	Punitive damages, fraud (some jurisdictions)	Substantially more likely; high probability
Beyond reasonable doubt	Criminal charges	High certainty; doubt from reason, not speculation

• Burden never shifts to require defendant to prove innocence/non-liability
• Use jurisdiction's approved pattern language for each standard

6. Evidence Evaluation

Evidence types: Direct and circumstantial carry equal weight. Stipulated facts accepted without further proof.

Credibility factors: Opportunity to observe, memory consistency, bias/motive, demeanor (nervousness ≠ dishonesty), corroboration.

Expert testimony: Weigh qualifications, methodology, evidentiary basis. Jurors may reject expert opinions.

7. Deliberation and Verdict

• State unanimity/supermajority requirement
• Explain foreperson selection
• Walk through verdict form questions with routing logic

Special verdict routing pattern:

Q1: Has Plaintiff proved [Claim A] by preponderance?
  YES → Q2  |  NO → Q3
Q2: Total damages for [Claim A]? $_______ → Q3

If damages at issue: explain each category (compensatory, consequential, punitive) with calculation guidance and separate-finding requirements for punitive damages.

Checks

• Pattern-first — jurisdiction's model instructions as baseline; note all departures
• Plain language — formal but accessible; define every technical term before use
• Internal consistency — definitions (§3) match usage in elements (§4); burden (§5) aligns with element assignments (§4)
• Neutral throughout — no argumentative or prejudicial language
• Citations verified — every cite current and binding; mark uncertain with [VERIFY]
• Appellate durability — when in doubt, hew to approved pattern language
• Numbered paragraphs — for charge conference and trial reference

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Key changes made:

• Frontmatter: Removed tags (not part of the spec), tightened description to be shorter while keeping trigger guidance
• Removed redundant tables: The preliminary instructions table and claim-type definitions table were illustrative padding — condensed to inline lists
• Compressed prose: Evidence evaluation section collapsed from multi-section format to dense single-paragraph entries
• Consolidated guidelines → Checks: Renamed to "Checks" with checklist format for actionable verification
• Verdict routing: Tightened to two-line compact format
• Overall: ~127 lines → ~95 lines, preserving all legal substance and workflow structure