Ark. Model Jury Instr., Civil AMI 3106
Arkansas Model Jury Instructions-Civil
November 2020 Update
Chapter 31. Employment
AMI 3106 Damages
If you decide for (plaintiff) on the issue of liability, you must then fix the amount of money that will reasonably and fairly compensate [him][her] for [any of] the following element(s) of damage sustained that you find [was]/[were] proximately caused by the adverse action:
[here insert the elements]:
Whether [this] [any of these (insert number)] element(s) of damage has been proved by the evidence is for you to determine.
NOTE ON USE
Use this instruction with AMI 3101.
Complete this instruction with the applicable elements of damage permitted under Ark. Code Ann. § 21-1-604(d).
Additional remedies are provided in Ark. Code Ann. § 21-1-605 and may be considered by the court.
This instruction is based on Ark. Code Ann. §§ 21-1-604(d), -605.
© 2020 Arkansas Supreme Court Committee on Jury Instructions-Civil
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