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Model Jury Instructions

The Committee on Model Jury Instructions for the Eighth Circuit proposes the instructions and verdict forms found here for use in civil and criminal cases to aid judges in their communication with jurors and to aid attorneys in the presentation of their cases. The Committee continually endeavors to use clear and simple language that reflects the law of the Eighth Circuit and that will prevail on appeal. That said, these proposed instructions are not the only method for instructing a jury properly. See United States v. Owens, 966 F.3d 700, 705-06 (8th Cir. 2020); United States v. Ridinger, 805 F.2d 818, 821 (8th Cir. 1986).  The model jury instructions are not promulgated by the Eighth Circuit.  Unless the use of a particular instruction is mandated by the Eighth Circuit in a decision, the “model” jury instructions “may serve as ‘helpful suggestions,’ but are ‘not binding on the district courts.’”  Id. at 705, citing United States v. Norton, 846 F.2d 521, 525 (8th Cir. 1988).

Every effort has been made to assure conformity with current Eighth Circuit law; however, it cannot be assumed that all model instructions in the form given necessarily will be appropriate under the facts of a particular case. The Civil and Criminal Manuals of Model Jury Instructions contain “Overviews,” “Notes on Use,” and “Committee Comments” that address issues concerning the instructions that are most frequently given. It is important to note that because each case turns on unique facts, instructions should be drafted or adapted to conform to the facts and the law in each case. 

The Committee on Model Jury Instructions reviews the instructions on an ongoing basis and annually makes any recommendations for amendment. The Committee welcomes user input on the content of the Model Instructions.

Model Jury Instructions Builder

The Jury Instructions Builder allows users to generate customized model jury instructions for civil or criminal cases. It can also be used to locate specific model instructions. All current Civil and Criminal Model Jury Instructions have been uploaded into the Jury Instructions Builder.

► Access the Builder at or click Jury Instructions Builder.