CACI No. VF-3901. Punitive Damages Against Employer or Principal for Conduct of a Specific Agent or Employee
Judicial Council of California Civil Jury Instructions (2023 edition)
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VF-3901.Punitive Damages Against Employer or Principal for
Conduct of a Specific Agent or Employee
We answer the questions submitted to us as follows:
1. Did [name of agent/employee] engage in the conduct with malice,
oppression, or fraud?
1. Yes No
1. If your answer to question 1 is yes, then answer question 2. If you
answered no, stop here, answer no further questions, and have
the presiding juror sign and date this form.
2. Was [name of employee/agent] an officer, director, or managing
agent of [name of defendant] acting on behalf of [name of
defendant]?
2. Yes No
2. [If your answer to question 2 is yes, then answer question 3. If
you answered no, stop here, answer no further questions, and
have the presiding juror sign and date this form.
3. What amount of punitive damages, if any, do you award [name of
plaintiff]? $ ]
Signed: Presiding Juror
Dated:
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 October 2008, December 2010
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.
Normally, this verdict form should be combined with the verdict form(s) on the
underlying cause(s) of action. Include question 3 if the trial is not bifurcated.
This form is based on CACI No. 3943, Punitive Damages Against Employer or
Principal for Conduct of a Specific Agent or Employee - Trial Not Bifurcated, and
CACI No. 3944, Punitive Damages Against Employer or Principal for Conduct of a
Specific Agent or Employee - Bifurcated Trial (First Phase).
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Depending on the facts of the case, alternative grounds for liability may be
substituted in question 2, as in CACI No. 3943.
DAMAGES VF-3901
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