Maryland Jury Instruction — 1.9.3 Miscellaneous Issues Retaliation is a legal instruction provided to the jury regarding cases involving retaliation in Maryland. Retaliation occurs when someone takes adverse action against another person in response to their engagement in protected activities, such as filing a complaint, reporting misconduct, or exercising legal rights. This instruction provides guidance to the jury on understanding the various aspects of retaliation claims and how they should be considered during the trial. Keywords: Maryland Jury Instruction, 1.9.3, Miscellaneous Issues, Retaliation Types of Maryland Jury Instruction — 1.9.3 Miscellaneous Issues Retaliation: 1. Retaliation Defined: This instruction focuses on providing a clear definition of retaliation, its elements, and the legal requirements needed to prove a retaliation claim. It helps the jury comprehend the essence of retaliation and its implications on the case at hand. 2. Protected Activities: This type of instruction emphasizes identifying specific activities protected by law, which may trigger retaliation claims. It explains to the jury that engaging in these activities is considered lawful, and retaliation against someone engaging in such activities is prohibited. 3. Adverse Action: In this instruction, the jury is educated about what constitutes adverse action, which typically involves any action that intends to punish or harm an individual for their protected activities. Examples of adverse action could include firing, demoting, intimidating, or creating a hostile work environment. 4. Causation: Causation instruction highlights the requirement of proving a direct link between the protected activity and the adverse action taken against the plaintiff. It informs the jury that the plaintiff must establish that there is a plausible connection between their engagement in protected activities and the defendant's retaliatory behavior. 5. Unlawful Motive: This instruction clarifies that in order to establish retaliation, it is essential to demonstrate that the defendant acted with an unlawful motive. It informs the jury that the motive behind the adverse action must be linked to the plaintiff's protected activities rather than any unrelated factors. 6. Remedies: This instruction discusses the potential outcome of a successful retaliation claim. It educates the jury about the potential remedies available to the plaintiff, such as reinstatement, compensation for lost wages, emotional distress damages, punitive damages, and attorney fees. Overall, Maryland Jury Instruction — 1.9.3 Miscellaneous Issues Retaliation covers the essential aspects of retaliation claims, including its definition, protected activities, adverse action, causation, unlawful motive, and potential remedies. By providing these instructions, the jury gains a comprehensive understanding of how to evaluate the evidence presented and make an informed decision based on the law.