Section 21 Damage Instruction

LibraryDamages 2012

MAI 5.01 [1996 Revision], entitled “Damages—Wrongful Death,” instructs the jury to award damages in a sum that will fairly and justly compensate the plaintiff for any damages the plaintiff and decedent sustained and the plaintiff is reasonably certain to sustain in the future as a direct result of the fatal injury.

Language instructing the jury to take into consideration
any aggravating circumstances may be added to MAI 5.01 [1981 Revision] if it is supported by the evidence. Rodriguez v. Suzuki Motor Corp., 936 S.W.2d 104, 110 (Mo. banc 1996). If
the evidence shows that a defendant knew or had reason to know that there...

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