HADDAD’S CIVIL TRIAL WEBBOOK

Judge William J. Haddad (Ret.)

Jury Instructions-IL > Motor Vehicle Accidents

How to Use these Instructions – Updated to 40 sets

Here are 40 sets of jury instructions selected from over 350 jury trials with verdicts from a few thousand dollars to $81 million. They are in WORD files for download, separation, and numbering. They are not presented as ironclad “law”, but rather to reflect the efforts of a jury trial judge and the highly skilled litigators who appeared in my courtroom in Chicago. They are offered for your use in the spirit of the camaraderie of our great profession.

• Bike vs. Truck ($1.4 Million) & Loss of Consortium ($50k) Wife struck in crosswalk on bicycle by a turning dump truck. Husband recovered in consortium.
• City Pothole – Special Interrogatories with Jury Charge Driver injured when car hits city pothole. See judge’s instruction on how jury should use special interrogatories.
• Intersection MVA – Paraplegia – $25 Million Multiple Defendants with cross complaints by drivers (one of whom was driving for IDOT)
• All Purpose Auto – Personal Injury  Complete set includes negligence, admitted negligence, counter-claims, agency, examples of issues’ allegations and code violations and non-IPI instruction on paid bills.
• All Purpose Auto – Property Damage  Complete set includes non-IPI subrogation and paid bills instructions, negligence, admitted negligence, agency, examples of issues’ allegations and code violations.
• Bifurcated Deliberations for Multiple Plaintiffs  Bifurcated deliberations injury claims where one party is directed out on negligence and the other is no.
• Trucking Death – $8 Million – Agency Defense 
• Wrongful Death – $9.1 Million – Head-On Collision  Court modified instructions during closings to cure improper remarks about special interrogatory.