Plaintiff Attorney Legal Information CenterBelow is an example of a verdict sheet that demonstrates the essential elements required for a thorough and precise jury deliberation process. Hopefully, this will help you draft your own, whether it is for trial or moot court.
- Another Example Verdict Sheet for Malpractice
Sample Verdict Sheet
IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND
CINDY FOARD – Plaintiff
v
MANDY DAVID – Defendant
CASE NO. 24-C-02-00980
Sample Verdict Sheet
- Do you find that Cindy Foard was negligent in the operation of his vehicle on September 6, 2023, and that his negligence was a proximate cause of the injuries to the Plaintiff, Mandy David?
- Yes _____ No _____
If you answered “Yes” to question 1, continue to question 2. If you answered “No” to question 1, conclude your deliberations and return your verdict for the Defendant.
- Do you find that the Plaintiff, Mandy David, was negligent in the operation of his motorcycle on September 6, 2023, and that his negligence was a proximate cause of his own injuries?
- Yes _____ No _____
If you answered “No” to question 2, continue to question 4. If you answered “Yes” to question 2, continue to question 3.
- Do you find that Plaintiff Mandy David was in a dangerous situation, and thereafter, Defendant Cindy Foard had a clear last chance to avoid injury to Plaintiff Mandy David, but failed to do so?
- Yes _____ No _____
If you answered “Yes” to question 3, continue to question 4. If you answered “No” to question 3, conclude your deliberations and return your verdict for the Defendant.
- What damages, if any, do you find for the Plaintiff, Mandy David, for:
- Past Medical Expenses: $____________________
- Past Lost Wages: $____________________
- Future Medical Expenses: $____________________
- Non-economic damages to include physical injury, suffering, inconvenience, and physical impairment in the past and into the future: $____________________
TOTAL DAMAGES $____________________
Date: ____________________ Jury Foreperson
What Is a Verdict Sheet?
A verdict sheet in a civil case is a document provided to the jury during deliberations, containing a series of questions they must answer to reach a decision. These questions are designed to be clear and precise, guiding the jury through the legal issues at hand. The sheet ensures that all necessary points are considered, covering all claims, defenses, and elements. It should be extremely uncomplicated, with the questions arranged in a logical sequence reflecting the key elements of the plaintiff’s claims and the defendant’s defenses, to help the jury systematically determine liability and compensation.
The verdict sheet also serves to ensure the jury’s findings are comprehensive and unambiguous. It includes specific categories for damages, such as past and future medical expenses, lost wages, and non-economic damages like pain and suffering. This detailed breakdown helps the jury allocate compensation accurately. The neutral phrasing of questions is crucial to avoid bias, ensuring that the jury’s responses are based solely on the evidence and legal instructions provided. Ultimately, the verdict sheet is a crucial tool in facilitating a clear, structured, and just outcome in civil litigation
Common Battleground Issues on Appeal Involving Verdict Sheets
In personal injury lawsuits, appeals often focus on several common issues related to verdict sheets. One major issue is inconsistent verdicts, where the answers to different questions on the verdict sheet contradict each other or the overall verdict, leading to ambiguity in the jury’s decision. Generally, courts will allow juries to be a little contradictory in civil personal injury lawsuits under the thinking that compromises were made. Judges are far more inflexible in criminal cases.
Misleading or prejudicial questions can also be grounds for appeal, especially if they suggest a particular answer or are too complex, causing confusion among jurors. You can’t write a jury sheet where a reasonable person could see it two ways.
Additionally, inconsistency with jury instructions can lead to appeals, particularly if the verdict sheet conflicts with the instructions or misinterprets the law. Proper damage guidance is crucial; ambiguous damage categories or incorrect legal standards for calculating damages can result in improper awards and subsequent appeals. You don’t want to be too specific or too general… but it really depends on the nature of the claim and the issues in dispute.
Finally, juror confusion stemming from complex legal language or poor formatting of the verdict sheet can be contested, as it may hinder the jury’s ability to make an informed and fair decision.
Importance of an Itemized Verdict Sheet
In most states, including Maryland, the use of an itemized verdict sheet is required in any action for personal injury or wrongful death claims, regardless of the amount or type of damages at issue. This ensures that all aspects of the case are considered and that the jury’s decision is comprehensive and well-documented.
But the legal significance of a verdict sheet varies by jurisdiction. The Maryland Supreme Court has held that a jury verdict sheet is not the final verdict rendered. Rather, it is a tool to assist the jury in reaching their decision. Additionally, the court determined that a verdict sheet does not qualify as a communication under Maryland Rule 4-326(d) that necessitates disclosure of its contents before the jury is dismissed.
Five Tips for Making a Verdict Sheet
- Clarity: Ensure that each question is clear and unambiguous to avoid confusion.
- Simplicity: Use simple and direct language.
- Relevance: Only include questions that are necessary to resolve the issues in the case.
- Logical Flow: Arrange questions in a logical sequence that reflects the elements of the case.
- Consistency: Ensure consistency in terminology and structure throughout the document.
More Resources
- How does the jury render its verdict in Maryland? Read the transcript from one motor tort trial.
- Model Verdict Sheets (in all types of cases)
- Sample Trial Documents (sample documents used in personal injury trials)
- Sample Jury Instructions (example jury instructions in personal injury cases)
- Sample Complaints (sample complaints in personal injury cases/medical malpractice cases)
- Sample Discovery (sample discovery in personal injury/medical malpractice cases)
- Sample Pleadings (sample pleadings in personal injury/medical malpractice cases)