Introduction

INTRODUCTION TO 2025 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, court 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: https://www.ce9.uscourts.gov/jury-instructions/model-civil [1]. 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 the most 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 juryinstructions@ce9.uscourts.gov [2].

            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 September 2025.

            The Committee thanks all of those members of the federal bench, bar, and legal academy, who have reviewed and commented on various parts of the book. The Committee also thanks District Judge Michael Simonn for his long-term dynamic leadership of the Committee from 2012 to 2023, as well as Aejung Yoon, the Committee’s staff attorney, for her invaluable diligence and dedication to the Committee.

CAVEAT 

            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
October 2025

Note

Brackets appear throughout this manual to allow users of this book to select or insert terms most appropriate for their cases. Words that are in brackets indicate that users may select one of the bracketed options. Words that are italicized, underlined, and in brackets are not the actual words a judge would say. Rather, these bracketed words indicate that users should insert terms most appropriate for their case. If there are two consecutive brackets, users will select one of the bracketed terms within each double bracket (e.g., “the defendant [[took] [obtained by extortion]] [[property] [money] [something of value]] belonging to or in the care, custody, control, management, or possession of [specify financial institution]” could become: “the defendant took money belonging to or in the care, custody, control, management, or possession of ABC Bank”).