California Civil Jury Instructions (CACI)
VF-1705. Defamation per quod (Private Figure—Matter of Private Concern)
Directions for Use
The special verdict forms in this section are intended only as models. They may need to be modified depending on the facts of the case.
This verdict form is based on CACI No. 1703, Defamation per quod—Essential Factual Elements (Private Figure—Matter of Public Concern).
Multiple statements may need to be set out separately, and if separate damages are claimed as to each statement, separate verdict forms may be needed for each statement because all the elements may need to be found as to each statement.
Users may need to itemize all the damages listed in question 7 if, for example, there are multiple defendants and issues regarding apportionment of damages under Proposition 51.
Question 4 may be modified by referring to one of the other two grounds listed in element 3 of CACI No. 1705, Defamation per quod—Essential Factual Elements (Private Figure—Matter of Private Concern), depending on which ground is applicable in the case.
Additional questions may be needed on the issue of punitive damages if the defendant is a corporate or other entity.
Omit question 9 if the issue of punitive damages has been bifurcated. If there are multiple causes of action, users may wish to combine the individual forms into one form. If different damages are recoverable on different causes of action, replace the damages tables in all of the verdict forms with CACI No. VF-3920, Damages on Multiple Legal Theories.
This form may be modified if the jury is being given the discretion under Civil Code section 3288 to award prejudgment interest on specific losses that occurred prior to judgment.