Entire Set of Civil Jury Instructions, Word | Entire Set of Civil Jury Instructions, PDF
Revised October 12, 2023
Table of Contents
Preliminary Sections
Section 101: Oaths
Section 200: Preliminary Instructions
Section 300: Evidence Instructions
Section 400: Substantive Instructions
Section 500: Damages
Section 600: Substantive Instructions – General
Section 700: Closing Instructions
Section 800 Supplemental Matters
Appendix B – Verdict Forms
Appendix C – Punitive Damage Instructions – cases prior to 10/1/99; revised March 2, 2023
Appendix D
Appendix E – Emergency Medical Treatment Claims Instructions for Causes of Action Arising prior to September 15, 2003
Preliminary Sections
- Committee Summary
- How to Use this Book
- The Theory and Technique of Charging a Jury with These Instructions
- Original Introduction from Inaugural Committee
- Orders of the Supreme Court Creating and Revising These Instructions
- Current Members of the Committee
- Members of the Committee Since Its Inception
Section 101 — Oaths
- 101.1 Oath of Jurors Before Voir Dire
- 101.2 Oath of Jurors After Voir Dire
- 101.3 Oath of a Witness
- 101.4 Oath of an Interpreter
Section 200 — Preliminary Instructions
Qualification Instructions; revised December 4, 2014
A. During Jury Selection
- 201.1 Description of the Case, revised March 2, 2023
- 201.2 Introduction of Participants and Their Roles; revised October 27, 2022
- 201.3 Explanation of the Voir Dire Process; revised October 27, 2022
B. After Jury Selected and Sworn
- 202.1 Introduction, revised March 2, 2023
- 202.2 Explanation of the Trial Procedure; revised October 27, 2022
- 202.3 Note-Taking by Jurors; revised February 1, 2018
- 202.4 Juror Questions; revised November 16, 2017
- 202.5 Jury to Be Guided by Official English Translation/Interpretation
- 202.6 Instruction on Adjournment; adopted October 27, 2022
Section 300 — Evidence Instructions
- 301.1 Deposition Testimony, Interrogatories, Stipulated Testimony, Stipulations, and Admissions
- 301.2 Instruction when First Item of Documentary, Photographic, or Physical Evidence Is Admitted
- 301.3 Instruction when Evidence Is First Published to Jurors
- 301.4 Instruction Regarding Visual or Demonstrative Aids
- 301.5 Evidence Admitted for a Limited Purpose
- 301.6 Jury to Be Guided by Official English Translation Interpretation
- 301.7 Jury to Be Guided by Official English Transcript of Recording in Foreign Language (Accuracy Not in Dispute)
- 301.8 Jury to Be Guided by Official English Translation/Interpretation — Transcript of Recording in Foreign Language (Accuracy in Dispute)
- 301.9 Disregard Stricken Matter
- 301.10 Instruction Before Recess; revised December 4, 2014
- 301.11 Failure to Maintain Evidence or Keep a Record
- 301.12 Redacted Documents
Section 400 — Substantive Instructions
NOTE ON USE
These substantive instructions should be followed by the applicable sections from Damages, Substantive Instructions — General, and Closing Instructions (Before Final Argument).
- 401 General Negligence
- 402 Professional Negligence
- 403 Products Liability
- 404 Insurer’s Bad Faith
- 405 Defamation
- 406 Malicious Prosecution
- 407 False Imprisonment
- 408 Tortious Interference with Business Relationships
- 409 Misrepresentation
- 410 Outrageous Conduct Causing Severe Emotional Distress
- 411 Civil Theft
- 412 Contribution Among Tortfeasors
- 413 Claim for Personal Injury Protection (PIP) Benefits (Medical Benefits only)
- 414 Intentional Tort As an Exception to Exclusive Remedy of Workers’ Compensation
- 415 Unlawful Retaliation
- 417 Unlawful Discrimination
- 418 Unlawful Retaliation Under Florida’s Public Sector Whistle-Blower Act
- 420 Negligent Infliction of Emotional Distress
- 451 Fiduciary Duty (Shared with Contract and Business)
401 General Negligence
- 401.1 Introduction
- 401.2 Summary of Claims
- 401.3 Greater Weight of the Evidence
- 401.4 Negligence
- 401.5 Negligence of a Child
- 401.6 Negligence of a Common Carrier
- 401.7 Res Ipsa Loquitur
- 401.8 Violation of Non-Traffic Penal Statute as Negligence per Se
- 401.9 Violation of Statute, Ordinance, or Regulation as Evidence of Negligence
- 401.10 Equal and Reciprocal Rights of Motorists and Pedestrians
- 401.11 Duty of Motorist Toward Children
- 401.12 Legal Cause
- 401.13 Preemptive Charges
- 401.14 Preliminary Issues — Vicarious Liability
- 401.15 Preliminary Issues — Common Carrier
- 401.16 Preliminary Issues — Premises Liability
- 401.17 Burden of Proof on Preliminary Issues
- 401.18 Issues on Plaintiff’s Claim — General Negligence
- 401.19 Issues on Plaintiff’s Claim — Common Carrier
- 401.20 Issues on Plaintiff’s Claim — Premises Liability, revised March 2, 2023
- 401.21 Burden of Proof on Main Claim; revised February 1, 2018
- 401.22 Defense Issues
- 401.23 Burden of Proof on Defense Issues; revised February 1, 2018
- 401.24 Counterclaims, Cross Claims, and Third Party Claims
- 401.25 Uninsured or Underinsured Motorist
402 Professional Negligence
NOTES ON USE
- Professional negligence claims are, for the most part, similar. The committee has, therefore, included all such claims in a single section. There are, however, some specific instructions that deal with issues unique to certain professions, such as instruction 402.4(d) (missing medical records) and instruction 402.12 (issues involved in certain legal malpractice claims). For cases involving allegations of negligence of professions other than medical or legal, instructions 402.11(a) and (b) and 402.12(a) and (b) should be appropriately modified.
- If a professional malpractice case involves a claim of product defect, jury instructions for such claims should be adopted from the applicable sections of this book.
- 402.1 Introduction
- 402.2 Summary of Claims
- 402.3 Greater Weight of the Evidence
- 402.4 Medical Negligence, revised September 13, 2018
- 402.5 Other Professional Negligence
- 402.6 Legal Cause
- 402.7 Legal Cause (Treatment Without Informed Consent)
- 402.8 Preemptive Charges
- 402.9 Preliminary Issues — Vicarious Liability; revised June 30, 2021
- 402.10 Burden of Proof on Preliminary Issues
- 402.11 Issues on Main Claim
- 402.12 Issues on Claim of Attorney Malpractice Arising Out of Civil Litigation
- 402.13 Burden of Proof on Main Claim; revised February 1, 2018
- 402.14 Defense Issues
- 402.15 Burden of Proof on Defense Issues; revised February 1, 2018
403 Products Liability
403 Products Liability Instructions contains all instructions outlined below.
- 403.1 Introduction
- 403.2 Summary of Claims
- 403.3 Greater Weight of the Evidence
- 403.4 Express Warranty
- 403.5 Implied Warranty of Merchantability
- 403.6 Implied Warranty of Fitness for Particular Purpose
- 403.7 Strict Liability
- 403.8 Strict Liability Failure to Warn
- 403.9 Negligence
- 403.10 Negligent Failure to Warn
- 403.11 Inference of Product Defect or Negligence
- 403.12 Legal Cause
- 403.13 Preliminary Issue
- 403.14 Burden of Proof on Preliminary Issue
- 403.15 Issues on Main Claim
- 403.16 Issues on Crashworthiness and “Enhanced Injury” Claims
- 403.17 Burden of Proof on Main Claim; Revised November 22, 2017
- 403.18 Defense Issues
- 403.19 Burden of Proof on Defense Issues
404 Insurer’s Bad Faith
- 404.1 Introduction
- 404.2 Summary of Claims or Contentions
- 404.3 Greater Weight of the Evidence
- 404.4 Insurer’s Bad Faith (Failure to Settle)
- 404.5 Medical Malpractice Insurer’s Bad Faith Failure to Settle
- 404.6 Legal Cause
- 404.7 Issues on Claim
- 404.8 Burden of Proof
- 404.9 Concluding Instruction when Court to Award Damages
- 404.10 Damages (Cases with Claims for Mental Distress)
- 404.11 Burden of Proof on Mental Distress Claim
- 404.12 Damages on Mental Distress Claim
- 404.13 Punitive Damages
405 Defamation
The Committee removed earlier published defamation instructions because portions of them were no longer accurate statements of law. The Committee will consider bringing forth a revised set of instructions in the future. (Deleted November 19, 2021.)
406 Malicious Prosecution
- 406.1 Introduction
- 406.2 Summary of Claims
- 406.3 Greater Weight of the Evidence
- 406.4 Probable Cause
- 406.5 Malice
- 406.6 Instituting or Continuing a Proceeding
- 406.7 Legal Cause
- 406.8 Issues on Claim
- 406.9 Burden of Proof on Claim
- 406.10 Defense Issues
- 406.11 Burden of Proof on Defense Issues
- 406.12 Malicious Prosecution Damages
407 False Imprisonment
- 407.1 Introduction
- 407.2 Summary of Claims
- 407.3 Greater Weight of the Evidence
- 407.4 Intentional Restraint
- 407.5 Legal Cause
- 407.6 Issues on Claim
- 407.7 Burden of Proof on Claim
- 407.8 Defense Issues
- 407.9 Burden of Proof on Defense Issues
- 407.10 False Imprisonment Damages
408 Tortious Interference with Business Relationships
- 408.1 Introduction
- 408.2 Summary of Claims or Contentions; revised February 17, 2022
- 408.3 Greater Weight of the Evidence
- 408.4 Legal Cause; revised February 17, 2022
- 408.5 Issues on Plaintiff’s Claim — Interference with Contract not Terminable at Will
- 408.6 Issues on Plaintiff’s Claim — Interference with Business Relations or with Contract Terminable at Will
- 408.7 Affirmative Defense — Competition
- 408.8 Affirmative Defense — Financial Interest
- 408.9 Unjustified Conduct — Malice
- 408.10 Burden of Proof on Defense Issues
- 408.11 Tortious Interference Damages
409 Misrepresentation
- 409.1 Introduction
- 409.2 Summary of Claims
- 409.3 Greater Weight of the Evidence
- 409.4 Negligence
- 409.5 Material Fact, revised March 2, 2023
- 409.6 Legal Cause
- 409.7 Issues on Plaintiff’s Claim — Fraudulent Misrepresentation
- 409.8 Issues on Plaintiff’s Claim — Negligent Misrepresentation
- 409.9 Issues on Plaintiff’s Claim — False Information Negligently Supplied for the Guidance of Others
- 409.10 Burden of Proof on Main Claim; revised November 22, 2017
- 409.11 Defense Issues
- 409.12 Burden of Proof on Defense Issues; revised February 1, 2018
- 409.13 Damages
410 Outrageous Conduct Causing Severe Emotional Distress
NOTE ON USE
The tort of “intentional infliction of emotional distress” is recognized in Florida. Metropolitan Life Insurance Co. v. McCarson, 467 So.2d 277 (Fla. 1985). The boundaries of this tort, particularly when the claimant is a third party affected by conduct occurring between the defendant and another person, are not clearly defined. Id.; Williams v. City of Minneola, 575 So.2d 683 (Fla. 5th DCA 1991); M. M. v. M. P. S., 556 So.2d 1140 (Fla. 3d DCA 1989); Ford Motor Credit Co. v. Sheehan, 373 So.2d 956 (Fla. 1st DCA 1979); Restatement (2d) of Torts, §46.
- 410.1 Introduction
- 410.2 Summary of Claims
- 410.3 Greater Weight of the Evidence
- 410.4 Extreme and Outrageous Conduct
- 410.5 Severe Emotional Distress
- 410.6 Legal Cause
- 410.7 Issues on Claim
- 410.8 Burden of Proof on Claim
411 Civil Theft
- 411.1 Introduction
- 411.2 Summary of Claims
- 411.3 Clear and Convincing Evidence
- 411.4 Legal Cause
- 411.5 Issues on Claim
- 411.6 Burden of Proof on Claim
- 411.7 Civil Theft Damages
412 Contribution Among Tortfeasors
NOTES ON USE
- A claim for contribution can be presented as a cross-claim in an injured party’s case or as an independent action. These instructions cover both types of claims. Instruction 412.1 deals with cross-claims in an injured party’s case and instruction 412.2 deals with third-party claims in an injured party’s action. These instructions are in proper form for use in negligence actions. If contribution is found to be appropriate in tort actions other than for negligence (but see the title to Ch. 75-198, Laws of Fla.), the instructions should be revised as necessary.
- The instructions for an independent action for contribution begin with instruction 412.3.
- Whether the contribution claim is a cross-claim, a third party action or an independent claim, it should be submitted to the jury with a form of special verdict by which the jury determines the relative degrees of fault of the defendants and any third party (see, for example, Model Instruction No. 6).
- 412.1 Contribution Sought by Cross-Claims Between Defendant Tortfeasors in Injured Party’s Original Action
- 412.2 Contribution Sought by Third Party Claim in Injured Party’s Original Action
- 412.3 Introduction for Independent Contribution Claim
- 412.4 Summary of Claims
- 412.5 Greater Weight of the Evidence
- 412.6 Negligence
- 412.7 Legal Cause
- 412.8 Issues on Claim and Burden of Proof; revised February 1, 2018
- 412.9 Defense Issue; revised February 1, 2018
413 Claim for Personal Injury Protection Insurance (PIP) Benefits (Medical Benefits Only)
- 413.1 Introduction
- 413.2 Summary of Claims or Contentions
- 413.3 Greater Weight of the Evidence
- 413.4 Issues on Claim
- 413.5 Burden of Proof on Claim
414 Intentional Tort as an Exception to Exclusive Remedy of Workers’ Compensation
- 414.1 Introduction
- 414.2 Summary of Claims
- 414.3 Clear and Convincing Evidence
- 414.4 Legal Cause
- 414.5 Issues on a Claim
- 414.6 Burden of Proof
415 UNLAWFUL RETALIATION
NOTE ON USE FOR 415
The instructions in this section are based upon F.S. 448.101–105 (Florida’s private-sector whistle-blower provisions). As to the right to trial by jury, see Fox v. City of Pompano Beach, 984 So. 2d 664 (Fla. 4th DCA 2008), and O’Neal v. Fla. A & M University, 989 So. 2d 6 (Fla. 1st DCA 2008) (right to jury trial pursuant to the Whistle-blower Act, F.S. 112.3187-31895); Rodriguez v. Casson-Mark Corp., 2008 WL 2949520 (M.D. Fla. July 28, 2008) (right to jury trial pursuant to the private-sector whistle-blower’s provisions, F.S. 448.101-105).
- 415.1 Introduction
- 415.2 Summary of Claims and Defenses
- 415.3 Greater Weight of the Evidence
- 415.4 Retaliation
- 415.5 Preliminary Issue – Adverse Employment Action
- 415.6 Burden of Proof on Preliminary Issue
- 415.7 Protected Activity
- 415.8 Legal Cause – Retaliation
- 415.9 Legal Cause – Damage
- 415.10 Issues on Plaintiff’s Claim
- 415.11 Burden of Proof on Claim
- 415.12 Unlawful Retaliation Damages
- 415.13 Defense Issue on Damages (Mitigation-Discharge)
- 415.14 Reduction of Damages to Present Value
416
See Standard Jury Instructions in Contracts and Business Cases
417 Unlawful Discrimination
NOTES ON USE FOR 417
The instructions in this section are based upon the Florida Civil Rights Act of 1992 (FCRA), which makes it unlawful for an employer to discriminate based upon race, color, religion, sex, pregnancy, national origin, age, handicap, or marital status. F.S. 760.01–760.11.
- 417.1 Introduction
- 417.2 Summary of Claims and Defenses
- 417.3 Greater Weight of the Evidence
- 417.4 Discrimination — Disparate Treatment
- 417.5 Legal Cause — Discrimination
- 417.6 Legal Cause — Damage
- 417.7 Issues on Plaintiff’s Claim
- 417.8 Burden of Proof on Claim
- 417.9 Unlawful Discrimination Damages
- 417.10 Affirmative Defense — Failure to Mitigate Lost Wages
- 417.11 Affirmative Defense — After-Acquired Evidence
- 417.12 Reduction of Damages to Present Value
418 Unlawful Retaliation Under Florida’s Public Sector Whistle-Blower Act
Notes on Use for 418
The instructions in this section are based upon F.S. 112.3187-112.31895 (Florida’s public-sector whistle-blower provisions). As to the right to trial by jury, see Fox v. City of Pompano Beach, 984 So. 2d 664 (Fla. 4th DCA 2008) and O’Neal v. Fla. A&M Univ., 989 So. 2d 6 (Fla. 1st DCA 2008).
- 418.1 Introduction
- 418.2 Summary of Claims and Defenses
- 418.3 Greater Weight of the Evidence
- 418.4 Retaliation
- 418.5 Preliminary Issue – Adverse Employment Action
- 418.6 Burden of Proof on Preliminary Issue
- 418.7 Protected Activity
- 418.8 Legal Cause – Retaliation
- 418.9 Legal Cause – Damage
- 418.10 Issues on Plaintiff’s Claim
- 418.11 Burden of Proof on Claim
- 418.12 Defense Issue – Adverse Employment Action Based on Other Grounds
- 418.13 Unlawful Retaliation Damages
- 418.14 Defense Issue on Damages (Mitigation – Discharge)
- 418.15 Reduction of Damages to Present Value
420 Negligent Infliction of Emotional Distress
NOTES ON USE FOR 420
The tort of “negligent infliction of emotional distress” is recognized in Florida. Champion v. Gray, 478 So. 2d 17 (Fla. 1985); Zell v. Meek, 665 So. 2d 1048 (Fla. 1995). The boundaries of this cause of action, the persons who may recover, and the relationships that form the basis of recovery will be established by the courts of this state on a case-by-case basis. Champion, at 21–22 (Alderman, J., concurring specially). These instructions should not be given if the plaintiff suffered an impact of any type. See generally Willis v. Gami Golden Glades, LLC, 967 So. 2d 846, 850 (Fla. 2007). The essence of impact is that the “outside force or substance, no matter how large or small, visible or invisible, and no matter that the effects are not immediately deleterious, touch or enter into the plaintiff’s body.” Id. If there was an impact, the jury instructions given would be governed by the principles for the type of tort involved and the resulting damages.
- 420.1 Introduction
- 420.2 Summary of Claims
- 420.3 Greater Weight of the Evidence
- 420.4 Negligence
- 420.5 Legal Cause
- 420.6 Issues on Plaintiff’s Claim
- 420.7 Burden of Proof on Main Claim
- 420.8 Defense Issues
- 420.9 Burden of Proof on Defense Issues
451 Fiduciary Duty (Shared Instructions with Contract and Business)
- 451.1 Introduction
- 451.2 Summary of Claims or Contentions
- 451.3 Greater Weight of the Evidence
- 451.4 Existence of Fiduciary Duty Disputed
- 451.5 Breach of Fiduciary Duty
- 451.6 Legal Cause
- 451.7 Preemptive Charges
- 451.8 Preliminary Issue — Vicarious Liability
- 451.9 Burden of Proof on Preliminary Issues
- 451.10 Issues on Main Claim
- 451.11 Burden of Proof on Main Claim
- 451.12 Defense Issues
- 451.13 Burden of Proof on Defense Issues
- 451.14 Model Form of Verdict for Breach of Fiduciary Duty
Section 500 Damages
A. Compensatory Damages
1. Personal Injury and Property Damages
- 501.1 Personal Injury and Property Damages: Introduction
- 501.2 Personal Injury and Property Damages: Elements
- 501.3 Motor Vehicle No-Fault Instruction
- 501.4 Comparative Negligence, Non-Party Fault and Multiple Defendants; amended January 23, 2020
- 501.5 Other Contributing Causes of Damages; revised April 21, 2016
- 501.6 Mortality Tables
- 501.7 Reduction of Damages to Present Value; revised April 21, 2016
- 501.8 Collateral Source Rule
- 501.9 Liability of Multiple Tortfeasors
2. Wrongful Death Damages
- 502.1 Wrongful Death Damages: Introduction
- 502.2 Wrongful Death Damages: Elements for Estate and Survivors; revised November 2, 2017
- 502.3 Wrongful Death Damages of Estate and Survivors: Separate Awards for Estate and Survivors
- 502.4 Wrongful Death Damages: Elements when There Are No Survivors
- 502.5 Comparative Negligence, Non-Party Fault, and Multiple Defendants
- 502.6 Mortality Tables
- 502.7 Reduction of Damages to Present Value; revised April 21, 2016
- 502.8 Liability of Multiple Tortfeasors
B. Punitive Damages
Note on Use for Punitive Damages Charges
Section 600 — Substantive Instructions, General
- 601.1 Weighing the Evidence
- 601.2 Believability of Witnesses; revised November 2, 2017
- 601.3 Jury to Be Guided by Official English Translation/Interpretation
- 601.4 Multiple Claims, Numerous Parties, Consolidated Cases
- 601.5 Concluding Instruction (Before Final Argument)
Section 700 — Closing Instructions
Section 800 — Supplemental Matters
- 801.1 Juror Questions During Deliberations
- 801.2 Readback or Playback of Testimony
- 801.3 Jury Deadlocked
- 801.4 Instructions upon Discharge of Jury
- 801.5 Inconsistent or Erroneous Verdict
Appendix A: Model Jury Instructions
Summary
The following Model Jury Instructions are included to illustrate the use of Florida Standard Jury Instructions. The hypothetical facts upon which each instruction is based are set forth before the instruction. The committee made arbitrary decisions about various factors involved in each hypothetical case, and the Model Instructions are not intended to be incorporated entirely into a court’s instruction.
The numbers of the instructions used in the examples are indicated within brackets. In instances in which changes have been made to adapt the standard instructions to the circumstances of the hypothetical case, the committee has italicized the instructions.
These Model Instructions are provided only as examples of how the instructions are intended to be used. Revisions in the Model Instructions often lag some time behind revisions in the substantive charges the use of which is illustrated in the Model Instructions. DO NOT, therefore, rely on the Model Instructions for correct wording when preparing instructions. Always refer to the standard instructions and forms provided in Parts I through VIII.
- Model Instruction No. 1: Automobile collision; comparative negligence; single claimant and defendant; no counterclaim; no-fault issue; witnesses testifying in foreign language; instructions for beginning and end of case; use of special verdict in burden of proof and damage instructions (revised January 23, 2020)
- Model Instruction No. 2: Automobile collision; driver’s comparative negligence including failure to wear seat belt; aggravation of pre-existing injury; multiple events (revised January 23, 2020)
- Model Instruction No. 3: Automobile collision; comparative negligence; wrongful death damages; Fabre issue (revised January 23, 2020)
- Model Instruction No. 4: Automobile collision; comparative negligence; claim and counterclaim (revised January 23, 2020)
- Model Instruction No. 5: Injury in three-car collision; settlement with injured party by one tortfeasor; independent contribution claim by him against others; reasonableness of settlement as well as liability contested (revised February 1, 2018)
- Model Instruction No. 6: Claimant suing three alleged joint tortfeasors; comparative negligence in issue; contribution shares to be determined in action (revised January 23, 2020)
- Model Instruction No. 7: Product liability case; negligence and strict liability claims; comparative negligence defense; aggravation of pre-existing injury
Appendix B: Verdict Forms
The following Model Verdict forms are included as examples of how issues can be submitted to the jury. They may be changed on a case-by-case basis depending on the rulings and facts in a particular case.
Historically, a general verdict on compensatory damages was considered appropriate, and that is the only form of verdict provided in the Florida Rules of Civil Procedure. See Fla.R.Civ.P. Form 1.986(a). However, with the advent of special verdicts and bifurcation of issues, it is now common for cases to be submitted to the jury with a special verdict. The committee has therefore drafted the following special verdict forms. None of the following are complete verdicts and in some instances more than one of these forms might apply.
Form of verdict itemizing damages introductory comment
1. Model form of verdict for general negligence with apportionment of fault (revised February 1, 2018)
2. Damages – Introductory Comment
- 2(a). Model form of verdict for personal injury damages
- 2(b). Model form of verdict for wrongful death damages (revised January 23, 2020)
- 3(a). Model form of verdict for bifurcated punitive damage cases
- 3(b). Model form of verdict for non-bifurcated punitive damage cases
- 4. Model form of verdict for statute of limitations defense in a medical negligence case (revised November 22, 2017)
- 5(a). Model form of verdict for emergency medical treatment; no issue as to the applicability of F.S. 768.13(2)(b)
- 5(b). Model form of verdict for emergency medical treatment; issue as to the applicability of F.S. 768.13(2)(b); no issue as to comparative negligence
- 5(c). Model form of verdict for emergency medical treatment; issues as to both applicability of F.S. 768.13(2)(b) and comparative negligence (revised February 1, 2018)
- 6. Model form of verdict for personal injury protection insurance benefits (PIP) (medical benefits only)
Appendix C
Punitive Damage Instructions for Causes of Action Arising Prior to October 1, 1999