Section 4.9 Approved Instructions

LibraryTort Law 2016

A. (§4.9) Approved Instructions

Missouri has approved jury instructions in NIED (negligent infliction of emotional distress) cases, notably using Missouri Approved Jury Instructions (Civil) 31.23 [2000 New] (7th ed. 2014). Per MAI 31.23 [2000 New], proper instruction in an NIED claim is as follows:

In a verdict directing instruction submitting negligent infliction of emotional distress, the essential elements are:
, such [negligence] [failure] involved an unreasonable risk of causing emotional distress, and
, defendant knew or by using ordinary care could have known of such risk,
...

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