WPI 45.00 Introduction
6 WAPRAC WPI 45.00Washington Practice Series TMWashington Pattern Jury Instructions--Civil
6 Wash. Prac., Wash. Pattern Jury Instr. Civ. WPI 45.00 (7th ed.)
Washington Practice Series TM
Washington Pattern Jury Instructions--Civil
April 2022 Update
Part V. Multiple Parties and Pleadings—Forms of Verdicts
Chapter 45. Forms of Verdicts
A. Simple Verdict Forms
WPI 45.00 Introduction
The verdict forms in this chapter are drafted to cover a variety of factual patterns as to parties, entities, and conduct that may be encountered in civil litigation. Particular care will be needed in selecting the appropriate verdict form and making any necessary adaptations to fit the case. When a special verdict form is used, it should cover every finding the jury may make to resolve the claims and defenses of each plaintiff and each defendant.
Most of the special verdict forms in this chapter use separate questions for negligence, causation, and damages. In some cases, it may be preferable to shorten the verdict form by combining questions, such as by combining questions about a party's negligence and causation. Recognizing this, the WPI Committee has provided two examples of how the verdict forms may combine questions related to negligence and causation. For a relatively routine special verdict form that combines these questions, see WPI 45.02 (Special Verdict Form—Contributory Negligence—Single Defendant). For an example of how to combine questions in a more complicated special verdict form, see the Comment to WPI 45.27 (Special Verdict Form—Personal Injury/Wrongful Death—Multiple Defendants—Contributory Negligence—“Empty Chairs”). In any given case, practitioners should use the approach that is the easiest for the jurors to understand and use.
If there is a claim by a married person, and the spouse or the marital community is joined as a plaintiff, then it may be necessary to revise the verdict form to set forth the separate damages claimed by each spouse and the community damages claimed. See the Comment to WPI 30.01.01 (Measure of Economic and Noneconomic Damages—Personal Injury—No Contributory Negligence).
Each verdict form used should be on a sheet with the heading as required for pleadings to include name of court, cause number, title of case, and title of verdict.
The concluding instruction and the verdict form itself should carefully explain the use of the verdict forms submitted to the jury. Concluding instructions are found at WPI 1.08 through 1.11.
Cross-references to verdict forms elsewhere in Volumes 6 and 6A are collected at WPI 45.30 (Special Verdict Forms—Other).
Pertinent statutes and court rules are:
| CR 49, CRLJ 49 | Verdicts |
| RCW 4.44.380 | Number of jurors required to render verdict |
| RCW 4.44.410 | General or special verdicts |
| RCW 4.44.420 | Verdict in actions for specific personal property (RCW 7.64) |
| RCW 4.44.440 | Inconsistency between special findings of fact and general verdict |
| RCW 4.44.460 | Receiving verdict and discharging jury |
| RCW 7.28.190 | Verdict where plaintiff's right to possession expires before trial |
[Current as of September 2018.]
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