Why Are Jury Instructions Important?

When a car accident case goes to trial, jury instructions will play a key role in determining the outcome of that case. The rules of trial and the issues the jury are to consider come from the jury instructions as annotated in the Missouri Approved Jury Instructions. These instructions are issued by the civil litigation committee of the Missouri Supreme Court. They are to be read by the judge to the jury prior to the juries' retirement to deliberate the merits of the case.

Jury instructions are very important because they lay the groundwork for how the trial will operate and set the legal standards the parties will have to meet. A great case can be worthless if it is not prepared with an eye toward proving the elements set forth in the jury instructions.

Jury instructions for car accidents have several different ways that a jury can hold a Defendant liable for a car accident. There are instructions for specific and general acts of negligence. Examples of specific acts of negligence include failure to drive on the right side of the road, failure to signal prior to turning or failure to stop at a stop sign. General acts of negligence include failure to keep a proper lookout, failure to yield, or following too closely.

Most types of car accidents are covered in the jury instructions. Sometimes, however, the jury instructions must be modified to cover specific types of negligence. It is important to make sure your attorney talks to the judge about keeping the instructions as close to the accepted instructions as possible. Straying too far from the accepted jury instructions can lead to a mistrial. Judges are aware of this and try to make their decisions as airtight as possible. No judge wants to have their decision found in error on appeal.

In a jury trial, a plaintiff who relies upon any disputed fact has the burden of causing the jurors to believe that such fact is more likely true than not. The plaintiff will present evidence and possibly expert testimony showing why their side meritorious. The Defendant will then present the same supporting their position. Jurors must only draw their conclusions from the evidence and any reasonable conclusions they draw from the evidence.

Jury instructions for civil trials in Missouri provide that 9 out of the 12 jurors must agree in order to return any verdict. A verdict must be signed by each juror that agrees to it.

Plaintiff’s must prove four (4) points to prevail on any negligence case. They must show that 1.) Defendant owed a duty to Plaintiff, 2.) Defendant breached that duty, 3.) that Plaintiff was injured and 4.) that damages from those injuries were caused or directly contributed to be caused by Plaintiff.

Here is an example of a negligence jury instruction used by Missouri Courts that informs jurors on how those elements must be met:

Your verdict must be for Plaintiff if you believe:

First, either:

Defendant’s automobile came into collision with the rear of plaintiff’s  automobile, or

Defendant failed to keep a careful lookout, and

Second, Defendant, in any one or more of the respects was thereby negligent,

and

Third, such negligence directly caused or directly contributed to cause damage  to Plaintiff.

The term “negligent” or “negligence” as used in this instruction means the failure to use the highest degree of care. The phrase “highest degree of care” means that degree of care that a very careful person would use under the same circumstances.

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