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

3-111 Illinois Forms of Jury Instruction 111.syn




Mary Catherine McGuire ;and Alexandria D'Italia

Chapter Summary


This chapter, Bodily Injury and Pain and Suffering, from Illinois Forms of Jury Instruction contains instructions regarding elements of noneconomic personal injury damages. Specifically, the chapter covers nonecomic personal injury damages, including disfigurement, disability and loss of normal life, increased risk of harm, and associated measures of damages and relevant calculations. It also addresses pain and suffering and emotional distress. The section covering aggravation of a preexisting condition covers the lack of a limit on recovery due to aggravation of a preexisting condition. The final section covers mitigation of damages.

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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See Chapter 110 for instructions on compensatory damages.

See Chapter 112 for coverage of damages for economic loss in personal injury actions.

See Chapter 114 for coverage of loss of consortium damages.

See Chapter 38 for instructions pertaining to burden of proof in negligence actions.

See Chapter 39 for instructions regarding affirmative defenses.


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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