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Illinois Forms of Jury Instruction
Copyright 2017, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

3-110 Illinois Forms of Jury Instruction 110.syn




Mary Catherine McGuire ;and Alexandria D'Italia

Chapter Summary


This chapter, Damages in General, from Illinois Forms of Jury Instruction contains introductory instructions with regard to damages for personal injury and property loss. The chapter covers the general measure of compensatory damages, measuring future damages, dealing with admitted liability and no liability, and collateral sources.

The chapter includes an instruction for use in personal injury actions in which evidence the plaintiff suffered injury from subsequent medical treatment has been presented. The instruction explains to the jury that the defendant's liability remains the same regardless of the conduct of the subsequent medical providers. The chapter includes instructions regarding the calculation of future damages, a pattern instruction regarding consideration of damages if the defendant admits liability, and a pattern instruction directing the jury not to consider damages if it determines the defendant is not liable. Finally, this chapter includes an instruction concerning the collateral source rule.

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 issues instructions and burden of proof instructions to use in a negligence action, see Chapter 38.

For specific instructions regarding the elements of duty, breach, and causation, as well as instructions regarding the affirmative defenses of contributory negligence and assumption of the risk, see Chapter 39.

Instructions concerning punitive damages are set forth in Chapter 113, and instructions pertaining to damages for loss of consortium are set forth in Chapter 114.

Recovery of damages in wrongful death actions is discussed in Chapter 115.

Chapters 60 through 100 cover tort actions against specific defendants.

General instructions for use after closing arguments, a model instruction, and a cover sheet to use in requesting jury instructions are presented in Chapter 2.


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.

See Damages in Tort Actions (Matthew Bender) for in-depth legal and policy analyses of compensatory and punitive damages in personal injury, wrongful death, and property damage cases, plus case annotations to all jurisdictions and examples of illustrative awards and settlements.

See Jury Instructions on Damages in Tort Actions (Matthew Bender) for a valuable resource to help lawyers write jury instructions relating to such topics as punitive damages, causation, comparative negligence, personal injuries, wrongs involving intangible property, and misrepresentations.
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