| name | jury-instructions |
| title | Jury Instructions |
| description | Drafts complete proposed jury instruction sets for U.S. litigation, including preliminary charges, elements, burden of proof, evidence evaluation, and verdict forms. Adapts to jurisdiction-specific pattern instructions. Use when drafting jury instructions, jury charges, verdict forms, or special interrogatories during trial preparation. |
| author | CaseMark |
| author_url | https://github.com/CaseMark/skills/tree/main/skills/legal/jury-instructions |
| license | Apache-2.0 |
| version | 0.1.0 |
| execution_mode | open |
| jurisdiction | us |
| practice | litigation |
| language | en |
Jury Instructions
Drafts proposed jury instructions tailored to case, jurisdiction, and claims at issue.
Prerequisites
Gather before drafting:
- Pleadings/pretrial order — complaint, answer, counterclaims, stipulated facts, MIL rulings
- Jurisdiction — state/federal, specific court, applicable pattern instructions
- Claims and defenses — all causes of action, affirmative defenses, statutory/common-law basis
- Verdict form type — general, special, or interrogatories
- Key evidence — expert witnesses, exhibits, stipulations
Instruction Sequence
Draft in this order using numbered paragraphs with descriptive headings.
1. Preliminary Instructions
Cover: jury's role as fact-finder, evidence limitations (no sympathy/prejudice/outside research), conduct rules (no independent investigation), deliberation expectations.
2. Case Statement
- Neutral, non-argumentative summary from undisputed facts, pleadings, and stipulations only
- Identify parties by name and role; state dispute nature and chronology
- Never use characterizations favorable to either side
3. Legal Definitions
- Define every legal term before it appears in elements instructions
- Source hierarchy: (1) statutory definitions → (2) pattern instructions → (3) controlling case law
- Build progressively — foundational terms first, compound concepts second
4. Elements Instructions
For each claim/charge/defense:
- Number every element
- Identify burden-bearing party per element
- Explain each element in case-specific context
- Address circumstantial-evidence inferences for mental-state elements
- Make contingent-claim sequencing explicit
5. Burden of Proof
