AMI 3501 Closing Instructions

You have now heard all the evidence and the instructions on the law you must apply in reaching your verdict. You soon will hear the lawyers’ closing arguments and then go to the jury room to decide this case. I have a few final instructions for you on how to proceed.

(a) Remember that you are to decide this case fairly, based only on the evidence presented in this courtroom and the law as instructed by me. Do not consider information from any other source. And do not allow sympathy, prejudice, or like or dislike of any party or any attorney in this case to influence your decision.

Keep in mind that the Basic Rule I have explained to you throughout the trial continues to apply during your deliberations: You are to discuss the case only among yourselves. Do not communicate about this case and the places and persons involved by any means whatsoever with anyone else at all, or look for or receive any information whatsoever about this case—including through Electronic Devices—other than the evidence in this courtroom and the law as I have instructed you, until your jury duty is complete and I have discharged you.

[(b) Any notes you may have taken during the trial may be taken to the jury room to use during your deliberations. Your notes are simply an aid to your own memory, and neither your notes nor those of any other juror are a substitute for your own memory or other jurors’ memory. Leave your notes in the jury room when you have concluded your deliberations.]

(c) Do not begin deliberations until all of you are assembled in the jury room. Once you are all there, the first thing for you to do is to elect one of you to act as foreperson during your deliberations. The foreperson should see to it that your discussions are orderly and that every one of you has a fair opportunity to be heard.

(d) If any of you needs to communicate with me for any reason, write me a note and give it to (the bailiff)(court personnel). In your note do not disclose any vote or division among yourselves.

At least nine of you must agree to arrive at a verdict.

If your verdict is unanimous, only the foreperson will sign your verdict form.

If your verdict is not unanimous, but nine or more of you agree on the verdict, then each of you who agrees must sign the verdict form. Those of you who do not agree must not sign the verdict form.]

I will now give you a verdict form with (a question)(questions) you must answer. (The answer to this question will be your verdict.)(Consider your answer to each of these questions as a separate verdict.)

Nine or more of you must agree on the answer to (the question)(any question) for that answer to be your verdict. (It is not necessary that the same nine or more of you agree on each verdict. Each question is separate.)

If your answer to (the question)(any question) is unanimous, only the foreperson will sign the verdict form (for that question). If your answer is not unanimous, but nine or more of you agree (on that answer), each of you who agrees must sign the answer. Those who do not agree must not sign.]