PATTERN JURY INSTRUCTIONS
1ST CIRCUIT COURT OF APPEALS
PART 2
TRIAL INSTRUCTIONS
2 PJI 1 | STIPULATIONS
ANNOTATIONS AND COMMENTS
2 PJI 2 | USE OF DEPOSITIONS
The deposition of [Witness], taken on [date], [is about to be/has been] presented to you [by a video/by reading the transcript]. Deposition testimony is entitled to the same consideration as live testimony, and you must judge it in the same way as if the witness was testifying in court.
[Do not place any significance on the behavior or tone of voice of any person reading the questions or answers.]
ANNOTATIONS AND COMMENTS
2 PJI 3 | USE OF RECORDED CONVERSATIONS AND TRANSCRIPTS
[In this case, there are two transcripts because there is a difference of opinion about what is said on the recording. You may disregard any portion of one or both transcripts if you believe they reflect something different from what you hear on the recording. It’s what you hear on the recording that is evidence – not the transcripts.]
ANNOTATIONS AND COMMENTS
2 PJI 4 | INTERIM STATEMENTS
ANNOTATIONS AND COMMENTS
2 PJI 5 | JUDICIAL NOTICE
ANNOTATIONS AND COMMENTS
2 PJI 6 | USE OF INTERROGATORIES
You must consider [Party]’s answers to as though [Party] gave the answers on the witness stand.
ANNOTATIONS AND COMMENTS
2 PJI 7 | IN-TRIAL INSTRUCTIONS ON NEWS COVERAGE
You must not read, listen to, or watch anything about this trial. It would violate your oath as a juror to decide this case on anything other than the evidence presented at trial and on your own common sense. You must decide this case exclusively on the evidence you receive here in court.
ANNOTATIONS AND COMMENTS
2 PJI 8 | CIVIL ALLEN CHARGE
Members of the jury:
This is an important case. The trial has been expensive in terms of time, effort, money, and emotional strain to both the plaintiff and the defendant. If you fail to agree on a verdict, the case remains open and may have to be tried again. A second trial would be costly to both sides, and there’s no reason to believe either side can try it again better or more exhaustively than they have tried it before you.
Any future jury would be selected in the same manner and from the same source as you. There’s no reason to believe that the case could ever be submitted to a jury of people more conscientious, more impartial, or more competent to decide it – or that either side could produce more or clearer evidence.
It’s your duty to consult with one another and to deliberate with a view to reaching an agreement – if you can do it without violating your individual judgment. You must not give up your honest beliefs about the evidence’s weight or effect solely because of other jurors’ opinions or just to return a verdict. You must each decide the case for yourself – but only after you consider the evidence with your fellow jurors.
You shouldn’t hesitate to reexamine your own views and change your opinion if you become convinced it’s wrong. To bring your minds to a unanimous result, you must openly and frankly examine the questions submitted to you with proper regard for the opinions of others and with a willingness to reexamine your own views.
If a substantial majority of you is for a verdict for one party, each of you who holds a different position ought to consider whether your position is reasonable. It may not be reasonable since it makes so little impression on the minds of your fellow jurors – who bear the same responsibility, serve under the same oath, and have heard the same evidence.
You may conduct your deliberations as you choose, but I suggest that you now carefully reexamine and reconsider all the evidence in light of the court’s instructions on the law. You may take all the time that you need.
I remind you that in your deliberations, you are to consider the court’s instructions as a whole. You shouldn’t single out any part of any instructions including this one, and ignore others.
You may now return to the jury room and continue your deliberations.
ANNOTATIONS AND COMMENTS
You might need to reference it during your pursuit of justice.
For instance, you might need to examine this item in order to protect yourself from organizations/judges/lawyers who break the law (see this example of a Florida judge who outright committed perjury).
Nevertheless – and as always – please get the justice you deserve.
Sincerely,
www.TextBookDiscrimination.com
