AMI 1604 Liability for Dangerous Animals—Comparative Fault

If you should find that the occurrence was proximately caused by the conduct of (defendant) in keeping the animal and not by any fault on the part of (plaintiff), then (plaintiff) is entitled to recover the full amount of any damages (he)(she) has sustained as a result of the occurrence.

If you find that the occurrence was proximately caused both by (defendant)'s conduct in keeping the animal and by fault on the part of (plaintiff), then you must determine their comparative fault.

If the fault of (plaintiff) is of less degree than the fault of (defendant), then (plaintiff) is entitled to recover any damages which you may find (he)(she) has sustained as a result of the occurrence after you have reduced them in proportion to the degree of (his)(her) own fault. On the other hand, if the fault of (plaintiff) is equal to or greater in degree than the fault of (defendant), then (plaintiff) is not entitled to recover any damages.