Ark. Model Jury Instr., Civil AMI 3105
Arkansas Model Jury Instructions-Civil
November 2020 Update
Chapter 31. Employment
AMI 3105 Defense
As a defense to the claim of (plaintiff), (defendant) contends that the action taken was due to:
a. [(plaintiff)’s misconduct] [or]
b. [(plaintiff)’s poor job performance] [or]
c. [a reduction in workforce unrelated to (plaintiff)’s engaging in a protected communication or act].
(Defendant) has the burden of proving this contention.
NOTE ON USE
Use this instruction with AMI 3101 if the employer asserts any of the three affirmative defenses provided in Ark. Code Ann. § 21-1-604(e).
This instruction is based on Ark. Code Ann. § 21-1-604(e)).
© 2020 Arkansas Supreme Court Committee on Jury Instructions-Civil
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