California Jury Instruction - Preliminary Instructions Before Opening Statements - Long Form

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This form contains sample jury instructions, to be used across the United States. These questions are to be used only as a model, and should be altered to more perfectly fit your own cause of action needs.

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FAQ

The Bluebook does not provide a format for the California jury instructions but the instructions provide their own suggested citation formats on the backs of their title pages: CACI Recommended Citation. CALCRIM Recommended Citation.

The opening statement should not contain argument; rather, it should be a factual statement that lasts from 10 to 30 minutes. Follow these guidelines to craft a winning and engaging opening statement that juries will remember.

Either before or after the closing arguments by the lawyers, the judge will explain the law that applies to the case to you. This is the judge's instruction to the jury. You have to apply that law to the facts, as you have heard them, in arriving at your verdict.

Juries in California are given California Jury Instruction CACI 418 or ?Presumption of Negligence per se? to help them determine when a defendant is negligent as a matter of law.

For a California statute, give the name of the code and the section number. For example, "Code of Civil Procedure, section 1011" or "Family Code, section 3461." For a federal statute, cite to the United States Code (abbreviated U.S.C.). For example, "28 U.S.C. section 351."

PATTERN JURY INSTRUCTIONS WHICH PROVIDE A BODY OF BRIEF, UNIFORM INSTRUCTIONS THAT FULLY STATE THE LAW WITHOUT NEEDLESS REPETION ARE PRESENTED; BASIC, SPECIAL, OFFENSE, AND TRIAL INSTRUCTIONS ARE INCLUDED.

CITE THIS PUBLICATION: Judicial Council of California Civil Jury Instructions (2023 edition) Cite these instructions: ?CACI No. _________.? Cite these verdict forms: ?CACI No. VF-_________.? This edition of CACI includes a number of additions and changes to the instructions, which were first published in 2003.

The full cite should be to "Judicial Council of California Civil Jury Instructions (year)". The short cite to particular instructions should be to "CACI No. ____."

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California Jury Instruction - Preliminary Instructions Before Opening Statements - Long Form