Sample Jury Instructions for Particular Types of Cases
The following represent instructions actually used in cases tried to verdict before Judge Denlow. They should be regarded as models. You should conduct your own independent research to confirm that the instructions still represent good law for purposes of your case. You should adapt these instructions to the particular issues of your case:
I. EMPLOYMENT DISCRIMINATION CASES:
A. Americans With Disabilities Act.

1. Wisch v. Whirlpool.
Case No. 94 C 7430 - verdict 5/22/96

[was plaintiff disabled? was plaintiff discriminated against?]

2. Senk v. Illinois Dept. of Human Services.
Case No. 96 C 5460 - verdict 1/16/98

[was plaintiff discriminated against by failing to receive a transfer?]

3. Price v. Interstate Warehousing, Inc.
Case No. 97 C 3618 - verdict 4/19/99

[was plaintiff discriminated against by being terminated when he had lifting restrictions after heart attack?]

4. Baumgardner v. County of Cook
Case No. 99 C 5788 - verdict 11/16/01

[was plaintiff with knee problem discriminated against by being transferred from laborer position to desk job?]

 

B. Rehabilitation Act.

1. Simon v. United States Postal Service.
Case No. 99 C 8297 - verdict 1/16/02

[was plaintiff discriminated against because of a disability or retaliated against because she requested an accommodation?]

C. Title VII and Age Discrimination Cases.

1. Stribling v. Nova Cellular.
Case No. 94 C 6985 - verdict 7/26/96

[was plaintiff denied opportunity to complete employment process due to his race, African American?]

2. Fernandez v. Governors State University.
Case No. 95 C 3709 - verdict 9/11/97

[was plaintiff fired from his position because of his race, caucasian?]

3. Sheehan v. Donlen.
Case No. 97 C 685 - verdict 10/23/97

[was plaintiff fired because she was pregnant?]

4. Thompson v. Altheimer & Gray.
Case No. 96 C 4319 - verdict 6/22/00

[was plaintiff denied promotion due to her race - African American?]

5. Flaherty v. Office of the Circuit Court Clerk of Cook County.
Case No. 00 C 565 - verdict 6/11/03

[was plaintiff sexually harassed by a supervisor? was plaintiff subjected to a hostile work environment? was plaintiff retaliated against?]

6. Newkirk v. AAA Chicago Motor Club.
Case No. 01 C 0615 - verdict 1/23/06

[was plaintiff denied promotion due to her race - African American or age (61)?]

7. Adcock v. B.D.’s Mongolian Barbeque.
Case No. 05 C 960 - verdict 7/20/06

[was plaintiff forced to go on leave early by defendant due to sex/pregnancy? was plaintiff terminated because of her sex/pregnancy? was plaintiff retaliated against?]

8. Lindsey v. Radioshack Corp.
Case No. 05 C 638 - verdict 6/8/07

[was plaintiff terminated because of his age?]

 

D. Fair Labor Standards Act.

1. Harkins, et al. v. Riverboat Services, Inc.
Case No. 99 C 123 - verdict 7/23/03

[did seaman exemption apply? Were plaintiffs terminated because they sued for overtime?]
II. SECTION 1983 OF THE CIVIL RIGHTS ACT:
A.  Excessive Force and False Arrest.

1.   Coffey v. Anderson.
Case No. 96 C 4859 - verdict 3/18/98

[was plaintiff beaten by officer while in police custody?]

2.  Nazario v. Martinez.
Case No. 98 C 1771 - verdict 10/16/98

[was plaintiff falsely arrested for attempted drug purchase?]

3.  Sbarboro v. Fiasche.
 Case No. 04 C 2888 - verdict 9/15/05

[was plaintiff falsely arrested?  was excessive force used while arresting plaintiff?]

4.  Mason v. City of Chicago..
 Case No. 07 C 4763 - verdict 9/22/09

[did defendants use excessive force? Did defendants fail to intervene? Was plaintiff falsely arrested? Was plaintiff maliciously prosecuted?]

B.  Retaliatory Discharge

1.  High v. City of Harvey, Illinois, et al.
Case No. 98 C 1819 - verdict 8/23/00

[was plaintiff terminated for failure to support a political candidate or because of her union activities?]

C.  Malicious Prosecution (Illinois State Action)

1.  Kiswani v. Cunningham
Case No. 05 C 4559 - verdict 6/12/98

[did defendant maliciously prosecute plaintiff on a charge of aggravated unlawful use of a weapon?]

D.  False Arrest, Malicious Prosecution (Illinois State Action), and Conspiracy

1.  Luckett v. Conlan
Case No. 07 C 3300 - verdict 7/30/08

[did defendants falsely arrest, maliciously prosecute, and conspire against plaintiff on a charge of possession of a controlled substance?]
III. Federal Employers' Liability Act
Personal Injury.

Collins v. Chicago and Northwestern Transportation.
Case No. 95 C 477 - verdict 1/29/97

[was railroad negligent in causing plaintiff a broken wrist and disability?]
IV. Automobile Accident
 
Personal Injury.

1.  Spizzirri v. Ristich.
Case No. 00 C 3159 - verdict 10/11/01

[was defendant negligent in causing auto accident in which plaintiff was injured?]

2.  Gann v. Oltesvig.
Case No. 06 C 2366 - verdict 3/28/07

[was defendant negligent and/or was plaintiff contributorily negligent in causing truck accident in which plaintiff died?]