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Illinois Forms of Jury Instruction
Copyright 2016, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

1-30 Illinois Forms of Jury Instruction 30.syn




Mary Catherine McGuire ;and Alexandria D'Italia

Chapter Summary


This chapter, Employment Contracts, from Illinois Forms of Jury Instruction sets forth instructions for employment disputes. Part A covers the Plaintiff's cause of action. Part B provides definitions, and Part C includes defenses. Part D covers damages.

Specifically, Part A addresses wrongful termination prior to expiration of an employment contract, wrongful termination without good cause, by reduction in rank or change of duties, for lack of good faith dissatisfaction, at-will employment in contravention of the statute, and wrongful termination in contravention of an employee handbook. Part B provides definitions of the employment contract, express and implied contracts, definite or indefinite duration, good cause, and good faith dissatisfaction with performance.

Part C's coverage of defenses includes discussion of the statute of limitations, the plaintiff's breach of employment duties, reasonable dissatisfaction with plaintiff's performance, termination in accordance with contract terms, voluntary resignation and modification of the employee handbook. Part D addresses damages including, the measure of damages, the employee's duty to mitigate, and mitigation of damages on wrongful termination.

Illinois Forms of Jury Instruction (Matthew Bender) provides a practical guide to drafting instructions that accurately reflect Illinois law and are comprehensible to jurors, combining both Illinois Pattern Jury Instructions (IPI) and non-IPI jury instructions. It covers general and cautionary instructions, as well as instructions in the substantive areas of contracts, torts, and statutory actions. The suggested instructions are accompanied by the case or statutory authorities on which the instruction is based, and a subsection explaining how and when an instruction should be used with guidelines for using alternative provisions.


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For discussion and instructions concerning contract formation and defenses to contract formation, see Chapters 10 and 11.

For discussion and instructions regarding performance and breach of contracts, see Chapter 12.

Chapter 13 covers defenses to nonperformance.

For instructions and discussion of general contract damages, see Chapter 14.


See Corbin on Contracts (Matthew Bender) for exhaustive and authoritative analysis of all the rules of contract law, including all exceptions and variations.

See Illinois Jurisprudence--Labor, Employment & Workers' Compensation (Matthew Bender) for thorough coverage of the current state of Illinois labor and employment law on issues such as employee health and safety, wages, benefits, hours, employment discrimination, employment of minors, agency and independent contractors, labor relations, and workers' compensation.

See Labor and Employment Law (Matthew Bender) for complete guidance to federal and state labor and employment law.

See Employment Law Deskbook (Matthew Bender) for coverage of every stage of the employer/employee relationship, with discussion of important issues confronting employers with respect to recruiting and hiring; wages, hours, and compensation; terms, conditions, and privileges of employment; discipline and discharge; equal employment opportunity statutes; discrimination claims; affirmative action; and sexual harassment.

See Illinois Jurisprudence (Matthew Bender) for an encyclopedia of Illinois law providing a one-step, comprehensive synthesis of more than 350 subject areas, covering criminal law and procedure, probate, family law, business relationships, personal injury and torts, property, commercial law, municipal law, labor and employment, insurance, civil procedure, education law, workers' compensation, health law, and elder law.
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