401.19 ISSUES ON PLAINTIFF’S CLAIM — COMMON CARRIER The [next] issues on (claimant’s) claim, for you to decide are: whether (defendant)...

401.18 ISSUES ON PLAINTIFF’S CLAIM — GENERAL NEGLIGENCE The [next] issues you must decide on (claimant’s) claim against (defendant) are:...

401.17 BURDEN OF PROOF ON PRELIMINARY ISSUES If the greater weight of the evidence does not support (claimant’s) claim on [this issue]...

401.16 PRELIMINARY ISSUES — PREMISES LIABILITY On (claimant’s) claim, there is a preliminary issue for you to decide. That issue is:...

401.15 PRELIMINARY ISSUES — COMMON CARRIER On (claimant’s) claim there is [a preliminary] [another] issue for you to decide. That issue...

401.14 PRELIMINARY ISSUES — VICARIOUS LIABILITY On the (claimant’s) claim there is a preliminary issue for you to decide. That issue is:...

401.13 PREEMPTIVE CHARGES The court has determined and now instructs you that a. Duty to use reasonable care: the circumstances at the...

401.12 LEGAL CAUSE a. Legal cause generally: Negligence is a legal cause of [loss] [injury] [or] [damage] if it directly and in natural...

401.11 DUTY OF MOTORIST TOWARD CHILDREN A motorist must use reasonable care to guard against the unpredictable and erratic behavior of...

401.10 EQUAL AND RECIPROCAL RIGHTS OF MOTORISTS AND PEDESTRIANS All persons [whether [pedestrians] [or] [motorists] [or] (other)] may use...

"401.7 RES IPSA LOQUITUR If you find that ordinarily the [incident] [injury] would not have happened without negligence, [and that the...

401.6 NEGLIGENCE OF A COMMON CARRIER Negligence is the failure to use reasonable care. (Defendant) is a common carrier. [The reasonable...

401.5 NEGLIGENCE OF A CHILD Reasonable care on the part of a child is the care that a reasonably careful child of the same age, mental...

401.4 NEGLIGENCE Negligence is the failure to use reasonable care, which is the care that a reasonably careful person would use under...

401.3 GREATER WEIGHT OF THE EVIDENCE “Greater weight of the evidence” means the more persuasive and convincing force and effect of the...

401.2 SUMMARY OF CLAIMS The claims [and defenses] in this case are as follows. (Claimant) claims that (defendant) was negligent in...

401.1 INTRODUCTION Members of the jury, you have now heard and received all of the evidence in this case. I am now going to tell you...

401.24 COUNTERCLAIMS, CROSS CLAIMS, AND THIRD PARTY CLAIMS NOTE ON USE FOR 401.24 Generally counterclaims, cross claims, and third party...

401.23 BURDEN OF PROOF ON DEFENSE ISSUES If the greater weight of the evidence does not support (defendant’s) defense[s] and the greater...

401.22 DEFENSE ISSUES If, however, the greater weight of the evidence supports [(claimant’s) claim] [one or more of (claimant’s) claims],...