ThomasMoreAI Verdict Form
Drafts a trial-ready verdict form guiding jury deliberations through structured questions on liability, defenses, and damages for each cause of action.
Prerequisites
Gather before drafting:
- Operative pleading — all causes of action and elements
- Answer / affirmative defenses — complete defense list including comparative fault
- Jury instructions — draft or final, for terminology alignment
- Damages evidence summary — categories supported by evidence
- Local rules — jurisdiction-specific form requirements (signatures, special verdict mandates)
Quick Start
- Mirror the caption from operative pleadings exactly
- Add introductory jury statement
- Draft sequentially numbered liability questions per cause of action
- Insert conditional affirmative defense questions
- Add damages questions conditioned on liability findings
- Include comparative fault allocation if at issue
- Add any court-required special interrogatories
- Close with jurisdiction-appropriate signature block
Core Sections
Caption
Copy verbatim from operative pleadings. Include court name, division, parties, case number, and title "VERDICT FORM."
Introductory Statement
Standard language: "We, the jury, duly empaneled and sworn in the above-entitled action, hereby return the following verdict:"
Liability Questions
One sequentially numbered question per cause of action:
- Plain language — "breached the contract," not "material breach of the subject agreement"
- State burden — "proven by a preponderance of the evidence"
- Answer format — Yes ___ / No ___ with adequate white space
- Order — foundational claims first, then dependent claims
Affirmative Defense Questions
For each complete-bar defense, insert a conditional question:
- Gate on the relevant liability "Yes" answer
- Ask whether defendant proved the defense applies
- If "Yes," direct jury to skip to Signature
- If "No," direct to next question
Damages
Condition all damages questions on liability "Yes" + defense "No" findings. Otherwise direct jury to skip to Signature.
Draft separate dollar-amount lines per category:
| Category | Include When |
|---|---|
| Compensatory (general) | Always if liability found |
| Compensatory (special) | Lost profits, medical expenses, property damage — itemize separately |
| Consequential | Pled and supported by evidence |
| Punitive | Only after predicate finding (malice/fraud/oppression per applicable state law) |
For punitive damages, require a separate predicate question before the amount question.
Comparative Fault
If at issue, add percentage allocation question requiring all parties to total 100%.
Special Interrogatories
Numbered questions for court-required factual findings: good faith, notice compliance, conditions precedent, timeliness / statute of limitations.
Signature Block
Standard closing: "We, the jury, certify that this is our verdict." Include date line, foreperson signature and printed name. Check local rules — some jurisdictions require all jurors to sign.
Pitfalls and Checks
- Sequential numbering — number continuously across all sections; never restart per section
- Terminology alignment — every question must mirror jury instruction language exactly
- Explicit skip instructions — every conditional must state where to go ("If No, skip to Question [N]")
- Completeness — cover every claim + every complete-bar defense so the court can enter judgment from answers alone
- No contradictions — structure conditionals to prevent logically inconsistent answers
- Jurisdiction adaptation — verify local requirements for punitive damages predicates, signature rules, and form mandates