Download

2 PJI 1.3 | SPECIAL VERDICT FORM: GENERAL DISCRIMINATION—MIXED MOTIVE CASE

1. Has [plaintiff] proven by a preponderance of the evidence that [protected characteristic] was a motivating factor in [defendant]’s decision to [specify adverse action]?

Yes____ No____

If “no,” answer no further questions. If “yes,” proceed to next question.



2. Has [defendant] proven by a preponderance of the evidence that it would nevertheless have taken the same action even if it had not considered [protected characteristic]?

Yes____ No____

If “yes,” answer no further questions. If “no,” proceed to next question.



3. What damages do you award [plaintiff] against [defendant]?

$_________________