Do you find from a preponderance of the evidence:
1. That [Plaintiff] was harassed because of [his/her] [race/sex]?
Answer Yes or No _____________
If your answer is “No,” this ends your deliberations, and your foreperson should sign and date the last page of this verdict form.
If your answer is “Yes,” go to the next question.
2. That [name of individual defendant] intentionally committed acts that created a hostile work environment for [Plaintiff], either personally or by directing others?
Answer Yes or No _____________
If your answer is “No,” this ends your deliberations, and your foreperson should sign and date the last page of this verdict form.
If your answer is “Yes,” go to the next question.
3. That [individual defendant] had supervisory authority over [Plaintiff] in the terms and conditions of [Plaintiff]’s employment?
Answer Yes or No _____________
If your answer is “No,” this ends your deliberations, and your foreperson should sign and date the last page of this verdict form.
If your answer is “Yes,” go to the next question.
[4. That [individual defendant]’s actions were “under color” of state law?
Answer Yes or No _____________]
[5. That the hostile work environment was the result of a “policy or custom” of [name of city]?
Answer Yes or No _____________]
[If you answered “No” to both Questions No. 4 and 5, this will end your deliberations, and your foreperson should go to the end of this verdict form to sign and date it.
If you answered “Yes” to either Question No. 4 or 5 (or both), go to the next question.]
6. That [Plaintiff] suffered damages because of the hostile work environment?
Answer Yes or No _____________
If your answer is “No,” this ends your deliberations, and your foreperson should sign and date the last page of this verdict form.
If your answer is “Yes,” go to the next question.
7. That [Plaintiff] should be awardeddamages to compensate for a net loss of wages and benefits to the date of your verdict?
Answer Yes or No _____________
If your answer is “Yes,” in what amount? $_____________
8. That [Plaintiff] should be awardeddamages to compensate for emotional pain and mental anguish?
Answer Yes or No _____________
If your answer is “Yes,” in what amount? $_____________
If you did not awarddamages in response to either Question No. 7 or Question No. 8, this will end your deliberations, and your foreperson should go to the end of this verdict form to sign and date it.
If you awardeddamages in response to Question No. 7 or Question No. 8 (or both), go to the next question.
9. That punitive damages should be assessed against [individual defendant]?
Answer Yes or No _____________
If your answer is “Yes,” in what amount? $_____________
SO SAY WE ALL.