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Intoduction to 2017 Print Edition 

            This Manual of Model Civil Jury Instructions ("Manual") has been prepared to help judges communicate more effectively with juries. 

            The instructions in this Manual are models. They are not mandatory, and they must be reviewed carefully before use in a particular case. They are not a substitute for the individual research and drafting that may be required in a particular case; nor are they intended to discourage judges from using their own forms and techniques for instructing juries. 

            In addition to its ongoing consideration of legislative developments and appellate court decisions that may affect these model instructions, the Jury Instructions Committee (the "Committee") welcomes suggestions from judges, staff and practitioners about possible revisions, additions and deletions. After careful assessment and research, the Committee updates and revises instructions from time to time as necessary. Revisions are available online at the following website: The revised instructions are later compiled and published in the printed version of the Manual. The Committee strongly recommends that the online version of any instruction be consulted to ensure that an up-to-date instruction is being considered. The Committee encourages users of this book to make suggestions for further revisions and updates. Suggestions may be submitted to

            This edition incorporates new and modified instructions. However, the print publication of the Manual necessarily presents only a snap-shot of an ongoing research and drafting process. Accordingly, even the most recent print edition does not necessarily represent the most up to date instructions. The entire publication and any later changes can be found online. This edition is current as to instructions approved as of January 2017. To assist users, the Committee has included a table listing the old instruction numbers from the 2007 print edition and the corresponding numbers in the present edition. 

            The Committee thanks the various members of the federal bench, bar and legal academy, who reviewed and commented on various parts of the book. The Committee also thanks Debra Landis, Esq., for her invaluable diligence, grace and expertise, some of which she provided on a voluntary basis. In addition, the Committee acknowledges with gratitude the contributions of Joseph Franaszek, Esq. For many years, Mr. Franaszek has worked with the Committee on a voluntary basis, providing careful research and drafting assistance, as well as a unique "institutional memory" that has enabled the changing membership of the Committee to understand how existing instructions came to be formulated. He and Ms. Landis have performed an invaluable service to the bench and bar and have earned the Committee’s enduring respect. 


            These model jury instructions are written and organized by judges who are appointed to the Ninth Circuit Jury Instructions Committee by the Chief Circuit Judge. 

            The Ninth Circuit Court of Appeals does not adopt these instructions as definitive. Indeed, occasionally the correctness or incorrectness of a given instruction may be the subject of a Ninth Circuit opinion. 

Ninth Circuit Jury Instructions Committee
January 2017