CACI No. VF-3501. Fair Market Value Plus Severance Damages
Judicial Council of California Civil Jury Instructions (2023 edition)Download PDF
VF-3501.Fair Market Value Plus Severance Damages
We answer the questions submitted to us as follows:
1. What was the fair market value of the property taken on [date of
Answer question 2.
2. What was the fair market value of the remaining property on
[date of valuation]? $
Answer question 3.
3. What would the fair market value of the remaining property
have been on [date of valuation] if the [name of public entity]’s
proposed project were completed as planned? $
Signed: Presiding Juror
After [this verdict form has/all verdict forms have] been signed, notify
the [clerk/bailiff/court attendant] that you are ready to present your
verdict in the courtroom.
New September 2003; Revised December 2010, December 2016, May 2020
Directions for Use
This verdict form is based on CACI No. 3501, “Fair Market Value” Explained, and
CACI No. 3511, Permanent Severance Damages.
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. For example, if the public
entity’s project was completed before the date of valuation, modify question 3
If the jury is being given the discretion under Civil Code section 3288 to award
prejudgment interest (see Bullis v. Security Pac. Nat’l Bank (1978) 21 Cal.3d 801,
814 [148 Cal.Rptr. 22, 582 P.2d 109]), give CACI No. 3935, Prejudgment Interest.
This verdict form may need to be augmented for the jury to make any factual
findings that are required in order to calculate the amount of prejudgment interest.