Drafting Jury Instructions and Verdict Forms
A Practice Note discussing key issues to consider when drafting and submitting civil jury instructions and verdict forms. This Note reviews the purpose, scope, and drafting of proposed jury instructions, the use of model or pattern jury instructions, and the procedural requirements for serving, filing, and objecting. It focuses on federal civil actions under the Federal Rules of Civil Procedure (FRCP), including FRCP 51 and FRCP 49. This Note also explores the different types of verdicts, such as special verdicts, general verdicts, and general verdicts with written questions, and examines the strategic considerations for each. It outlines the critical steps for making timely and proper objections to preserve issues for appeal and reviews the timing of the court's instructions to the jury. While centered on federal practice, it also provides valuable insights that may be applicable in many state court proceedings where the process is similar.
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