Texas Pattern Jury Charges—Business, Consumer, Insurance & Employment (2022 Ed.)
PJC Charges
Chapter 100 Admonitory Instructions
| 100-1 | Instructions to Jury Panel before Voir Dire Examination |
| 100-2 | Instructions to Jury after Jury Selection |
| 100-3 | Charge of the Court |
| 100-3A | Charge of the Court—Twelve-Member Jury |
| 100-3B | Charge of the Court—Six-Member Jury |
| 100-3 alt addl certificate | |
| 100-4 | Additional Instruction for Bifurcated Trial |
| 100-4 addl instr pre-2003 | |
| 100-4 alt addl certificate | |
| 100-5 | Instructions to Jury after Verdict |
| 100-6 | Instruction to Jury If Permitted to Separate |
| 100-7 | Instruction If Jury Disagrees about Testimony |
| 100-8 | Circumstantial Evidence (Optional) |
| 100-9 | Instructions to Deadlocked Jury |
| 100-10 | Privilege—Generally No Inference |
| 100-11 | Fifth Amendment Privilege—Adverse Inference May Be Considered |
| 100-12 | Parallel Theories on Damages |
| 100-13 | Proximate Cause |
| 100-14 | Instruction on Spoliation |
Chapter 101 Contracts
| 101-1 | Basic Question—Existence |
| 101-1 alt Q bind terms | |
| 101-1 alt Q future agree | |
| 101-1 addl instr consideration | |
| 101-2 | Basic Question—Compliance |
| 101-2A | Breach When Only One Party Claims a Material Breach |
| 101-2A alt Q limited | |
| 101-2A addl instr code duty | |
| 101-2A addl instr good faith | |
| 101-2B | Breach When More Than One Party Claims a Material Breach |
| 101-3 | Question and Instruction on Declaration of Meaning of Ambiguous Provisions |
| 101-4 | Question and Instruction on Reformation as an Affirmative Cause of Action |
| [PJC 101.5 and 101.6 are reserved for expansion.] | |
| 101-7 | Defenses—Basic Question |
| 101-8 | Question on Main Purpose Doctrine |
| 101-9 | Instruction on Formation of Agreement |
| 101-10 | Instruction on Offer and Acceptance |
| 101-10 addl instr modification | |
| 101-11 | Instruction on Withdrawal or Revocation of Offer |
| 101-12 | Instruction on Ambiguous Provisions |
| 101-13 | Instruction on Price |
| 101-14 | Instruction on Time of Compliance |
| 101-15 | Instruction on Authority |
| 101-16 | Instruction on Ratification |
| 101-17 | Instruction on Materiality |
| 101-18 | Defenses—Instruction on Plaintiff’s Material Breach When Only One Party Claims a Material Breach |
| 101-19 | Defenses—Instruction on Anticipatory Repudiation |
| 101-20 | Defenses—Instruction on Waiver |
| 101-21 | Defenses—Instruction on Release |
| 101-22 | Defenses—Instruction on Equitable Estoppel |
| 101-23 | Defenses—Instruction on Duress |
| 101-24 | Defenses—Instruction on Undue Influence |
| 101-25 | Defenses—Instruction on Mutual Mistake of Fact |
| 101-26 | Defenses—Instruction on Mutual Mistake—Scrivener’s Error |
| 101-27 | Defenses—Instruction on Novation |
| 101-28 | Defenses—Instruction on Modification |
| 101-29 | Defenses—Instruction on Accord and Satisfaction |
| 101-30 | Defenses—Instruction on Mental Capacity |
| 101-31 | Defenses—Instruction on Fraudulent Inducement |
| 101-32 | Trade Custom (Comment) |
| 101-32 instr trade custom | |
| 101-32 instr trade custom awareness | |
| 101-33 | Conditions Precedent (Comment) |
| 101-33 Q waiver | |
| 101-34 | Third-Party Beneficiaries (Comment) |
| 101-34 Q third party | |
| 101-35 | Defenses—Statute of Frauds (Comment) |
| [PJC 101.36–101.40 are reserved for expansion.] | |
| 101-41 | Question on Promissory Estoppel |
| 101-42 | Question and Instruction on Quantum Meruit |
| 101-43 | Money Had and Received (Comment) |
| 101-44 | Unjust Enrichment (Comment) |
| [PJC 101.45 is reserved for expansion.] | |
| 101-46 | Construction Contracts Distinguished from Ordinary Contracts (Comment) |
| 101-47 | Construction Contracts—Question and Instruction—Misapplication of Trust Funds under the Texas Construction Trust Funds Act |
| 101-47 addl instr intent defraud | |
| 101-47 prelim Q trustee | |
| 101-47 addl instr residential | |
| 101-48 | Construction Contracts—Misapplication of Trust Funds—Affirmative Defenses—Basic Question |
| 101-48 alt Q excuse | |
| 101-49 | Construction Contracts—Misapplication of Trust Funds—Affirmative Defenses—Instructions |
| 101-50 | Question on Prompt Payment to Contractors and Subcontractors |
| 101-51 | Question on Good-Faith Dispute |
| 101-51 addl instr residential | |
| [PJC 101.52–101.55 are reserved for expansion.] | |
| 101-56 | Insurance Contracts Distinguished from Other Contracts (Comment) |
| 101-57 | Insurance Contracts—Compliance—Specific Policy Language |
| 101-58 | Insurance Contracts—Coverage and Damages Question—Specific Policy Language |
| 101-59 | Insurance Contracts—Exclusions, Limitations, Avoidance, and Other Affirmative Defenses—Specific Policy Language |
| 101-59 alt Q excuse | |
| 101-60 | Insurance Contracts—Conditions Precedent and Prejudice (Comment) |
| 101-60 alt Q condition precedent | |
| 101-60 alt Q prejudice |
Chapter 102 The Texas Deceptive Trade Practices Act and Chapter 541 of the Texas Insurance Code
| 102-1 | Question and Instructions on False, Misleading, or Deceptive Act or Practice (DTPA § 17.46(b)) |
| 102-2 | Description of Goods or Services or Affiliation of Persons (DTPA § 17.46(b)(5)) |
| 102-2 alt instr affiliation | |
| 102-3 | Quality of Goods or Services (DTPA § 17.46(b)(7)) |
| 102-4 | Misrepresented and Unlawful Agreements (DTPA § 17.46(b)(12)) |
| 102-4 alt instr unlawful | |
| 102-5 | Failure to Disclose Information (DTPA § 17.46(b)(24)) |
| 102-6 | Other “Laundry List” Violations (DTPA § 17.46(b)) (Comment) |
| 102-7 | Question and Instructions on Unconscionable Action or Course of Action (DTPA §§ 17.50(a)(3) and 17.45(5)) |
| 102-8 | Question and Instructions on Warranty (DTPA § 17.50(a)(2); Tex. UCC §§ 2.313–.315) |
| 102-9 | Express Warranty—Goods or Services (DTPA § 17.50(a)(2); Tex. UCC § 2.313) |
| 102-9 alt Q-instrs knowledge | |
| 102-10 | Implied Warranty of Merchantability—Goods (DTPA § 17.50(a)(2); Tex. UCC § 2.314(b)(3)) |
| 102-10 alt elements merchantability | |
| 102-11 | Implied Warranty of Fitness for Particular Purpose—Goods (DTPA § 17.50(a)(2); Tex. UCC § 2.315) |
| 102-12 | Implied Warranty of Good and Workmanlike Performance—Services (DTPA § 17.50(a)(2)) |
| 102-13 | Implied Warranty of Habitability (DTPA § 17.50(a)(2)) |
| 102-14 | Question on Insurance Code Chapter 541 |
| [PJC 102.15 is reserved for expansion.] | |
| 102-16 | Misrepresentations or False Advertising of Policy Contracts—Insurance (Tex. Ins. Code § 541.051(1)) |
| 102-17 | False Information or Advertising—Insurance (Tex. Ins. Code § 541.052) |
| 102-18 | Unfair Insurance Settlement Practices (Tex. Ins. Code § 541.060) |
| 102-18 addl instr liability | |
| 102-19 | Misrepresentation—Insurance (Tex. Ins. Code § 541.061) |
| [PJC 102.20 is reserved for expansion.] | |
| 102-21 | Question and Instructions on Knowing or Intentional Conduct |
| 102-21 alt def knowingly | |
| 102-21 addl def intentionally | |
| 102-22 | Defenses to Deceptive Trade Practices Act and Insurance Code Chapter 541 Claims (Comment) |
| 102-23 | Statute of Limitations (DTPA § 17.565; Tex. Ins. Code § 541.162) |
| 102-23 addl Q inducement | |
| 102-24 | Counterclaim—Bad Faith or Harassment (DTPA § 17.50(c); Tex. Ins. Code Ch. 541, Subch. D) (Comment) |
| 102-25 | Prompt Payment of Claims Act—Violation of Insurer’s Duty to Acknowledge Notice of Claim, Commence Investigation, and Request Information after Receiving Notice of Claim (Tex. Ins. Code § 542.055) |
| 102-25 addl Q date | |
| 102-25 addl instr notice | |
| 102-25 addl instr def agent | |
| 102-25 addl instr plaintiff agent | |
| 102-25 alt def business day | |
| 102-26 | Prompt Payment of Claims Act—Violation of Insurer’s Duty to Notify Claimant of Acceptance, Rejection, or Need for More Time after Receiving All Necessary Information Reasonably Requested from Claimant (Tex. Ins. Code § 542.056) |
| 102-26 addl Q date | |
| 102-26 addl instr def agent | |
| 102-26 addl instr plaintiff agent | |
| 102-26 addl Qs exception | |
| 102-27 | Prompt Payment of Claims Act—Violation of Insurer’s Duty to Pay after Notice to Claimant that Insurer Will Pay All or Part of Claim (Tex. Ins. Code § 542.057) |
| 102-27 addl Q date | |
| 102-27 addl instr def agent | |
| 102-27 addl instr plaintiff agent | |
| 102-27 alt def business day | |
| 102-28 | Prompt Payment of Claims Act—Violation of Insurer’s Duty to Pay Claim within Sixty Days of Receipt of All Necessary Information Reasonably Requested from Claimant (Tex. Ins. Code § 542.058) |
| 102-28 addl Q date | |
| 102-28 addl instr def agent | |
| 102-28 addl instr plaintiff agent |
Chapter 103 Good Faith and Fair Dealing
| 103-1 | Common-Law Duty of Good Faith and Fair Dealing—Question and Instruction on Insurance Claim Denial or Delay in Payment |
| 103-2 | Duty of Good Faith under the Uniform Commercial Code (Comment) |
| 103-3 | Duty of Good Faith by Express Contract (Comment) |
Chapter 104 Fiduciary Duty
| 104-1 | Question and Instruction—Existence of Relationship of Trust and Confidence |
| 104-2 | Question and Instruction—Breach of Fiduciary Duty Defined by Common Law—Burden on Fiduciary |
| 104-3 | Question and Instruction—Breach of Fiduciary Duty Defined by Common Law—Burden on Beneficiary |
| 104-4 | Question and Instruction—Breach of Fiduciary Duty Defined by Statute or Agreement—Burden on Fiduciary |
| 104-5 | Question and Instruction—Breach of Fiduciary Duty Defined by Statute or Agreement—Burden on Beneficiary |
Chapter 105 Fraud and Negligent Misrepresentation
| 105-1 | Question on Common-Law Fraud—Intentional Misrepresentation |
| 105-2 | Instruction on Common-Law Fraud—Intentional Misrepresentation |
| 105-3 | Definitions of Misrepresentation—Intentional Misrepresentation |
| 105-3A | Factual Misrepresentation |
| 105-3B | Promise of Future Action |
| 105-3C | Opinion Mixed with Fact |
| 105-3D | False Statement of Opinion |
| 105-3E | Opinion Made with Special Knowledge |
| 105-4 | Instruction on Common-Law Fraud—Failure to Disclose When There Is Duty to Disclose |
| 105-5 | Question on Statute of Limitations—Common-Law Fraud |
| [PJC 105.6 is reserved for expansion.] | |
| 105-7 | Question on Statutory Fraud (Real Estate or Stock Transaction) |
| 105-8 | Instruction on Statutory Fraud—Factual Misrepresentation |
| 105-9 | Instruction on Statutory Fraud—False Promise |
| 105-10 | Question and Instructions on Benefiting from Statutory Fraud |
| 105-11 | Question and Instruction on Actual Awareness of Statutory Fraud |
| 105-11 alt instr pre-2003 | |
| 105-12 | Question and Instructions on Violation of Texas Securities Act—Factual Misrepresentation |
| 105-13 | Instruction on Violation of Texas Securities Act—Material Fact—Prediction or Statement of Belief |
| 105-14 | Question on Defenses to Violation of Texas Securities Act—Factual Misrepresentation |
| 105-15 | Question on Defenses to Violation of Texas Securities Act—Buyer |
| 105-16 | Question on Violation of Texas Securities Act—Control-Person Liability |
| 105-16 addl instr control | |
| 105-17 | Question on Defense to Control-Person Liability |
| 105-18 | Question and Instructions on Violation of Texas Securities Act—Aiding Violation |
| 105-19 | Question and Instruction on Negligent Misrepresentation |
| [PJC 105.20–105.24 are reserved for expansion.] | |
| 105-25 | Question and Instruction on Transfers Fraudulent as to Present and Future Creditors—Actual Fraud (Tex. Bus. & Com. Code § 24.005(a)(1)) |
| 105-25 def insider | |
| 105-25 def affiliate | |
| 105-25 instr insolvent | |
| 105-25 def transfer | |
| 105-26 | Question on Reasonably Equivalent Value—Constructive Fraud (Tex. Bus. & Com. Code §§ 24.005(a)(2), 24.006(a)) |
| 105-26 instr value | |
| 105-26 def transfer | |
| 105-27 | Question on Constructive Fraud (Tex. Bus. & Com. Code §§ 24.005(a)(2), 24.006(a)) |
| 105-27 instr insolvent | |
| 105-28 | Question on Constructive Fraud—Transfer to Insider (Tex. Bus. & Com. Code § 24.006(b)) |
| 105-28 def insider | |
| 105-28 def affiliate | |
| 105-28 instr insolvent | |
| 105-28 def transfer | |
| 105-29 | Question and Instruction on Good Faith and Reasonably Equivalent Value—Affirmative Defense to Fraudulent Transfer Based on Actual Fraud (Tex. Bus. & Com. Code § 24.009(a)) |
| 105-29 instr value | |
| 105-30 | Question on Affirmative Defense for Insider (Tex. Bus. & Com. Code § 24.009(f)) |
| 105-31 | Question on Extinguishment of Cause of Action (Tex. Bus. & Com. Code § 24.010) |
| 105-32 | Remedies for Fraudulent Transfers (Tex. Bus. & Com. Code § 24.008) (Comment) |
| 105-32 addl Q 1 amount | |
| 105-32 addl Q 2 amount | |
| 105-32 addl Q 3 amount |
Chapter 106 Interference with Existing and Prospective Contract
| 106-1 | Question and Instruction—Intentional Interference with Existing Contract |
| 106-2 | Question—Defense of Legal Justification |
| 106-3 | Wrongful Interference with Prospective Contractual or Business Relations (Comment) |
| 106-4 | Contracts Terminable at Will or on Notice (Comment) |
Chapter 107 Employment
| 107-1 | Breach of Employment Agreement (Comment) |
| 107-1 alt Q property interest | |
| 107-2 | Instruction on Good Cause as Defense to Early Discharge |
| 107-3 | Question on Wrongful Discharge for Refusing to Perform an Illegal Act |
| 107-4 | Question and Instruction on Retaliation under Texas Whistleblower Act |
| 107-4 addl Q good faith belief | |
| 107-5 | Question and Instruction on Retaliation for Seeking Workers’ Compensation Benefits |
| 107-5 addl instr proceeding | |
| 107-6 | Question and Instruction on Unlawful Employment Practices |
| 107-6 alt Qs-instrs disparate impact | |
| 107-6 alt Qs age | |
| 107-6 addl instr cat paw theory | |
| 107-7 | Question on After-Acquired Evidence of Employee Misconduct |
| 107-8 | Instruction on Damages Reduction for After-Acquired Evidence of Employee Misconduct |
| 107-9 | Question and Instruction on Retaliation |
| 107-9 addl instr cat paw theory | |
| 107-10 | Instruction on Constructive Discharge |
| 107-11 | Instruction on Disability |
| 107-11A | Instruction on Disability (Actual, or Record of) |
| 107-11A addl instr disability | |
| 107-11A addl instr mitigation | |
| 107-11A addl Q qualified individual | |
| 107-11B | Question and Instruction on Disability (Regarded as) |
| 107-12 | Question and Instruction on Failure to Make Reasonable Workplace Accommodation |
| 107-13 | Question and Instruction on Undue Hardship Defense |
| 107-14 | Question on Good-Faith Effort to Make Reasonable Workplace Accommodation |
| 107-15 | Instruction on Sex Discrimination |
| 107-16 | Instruction on Religious Observance or Practice |
| 107-17 | Question and Instruction on Defense of Undue Hardship to Accommodate Religious Observances or Practices |
| 107-18 | Question Limiting Relief in Unlawful Employment Practices |
| 107-19 | Question and Instruction on Bona Fide Occupational Qualification Defense |
| 107-20 | Question on Harassment |
| 107-21 | Question and Instruction on Sexual Harassment |
| 107-21 alt instr pre-2021 | |
| 107-21 alt instr personal liability | |
| 107-22 | Instruction on Harassment by Nonsupervisory Employee (Hostile Environment) |
| 107-23 | Instruction on Harassment by Supervisory Employee Not Involving Tangible Employment Action (Hostile Environment) |
| 107-24 | Question and Instruction on Affirmative Defense to Harassment Where No Tangible Employment Action Occurred |
| 107-25 | Question Limiting Relief for Retaliation under Texas Whistleblower Act |
Chapter 108 Piercing the Corporate Veil
| 108-1 | Basic Question |
| 108-2 | Disregarding the Corporate Fiction in Contract-Related Cases (Comment) |
| 108-3 | Instruction on Alter Ego |
| 108-3A | Instruction on Alter Ego in Cases Governed by Tex. Bus. Orgs. Code § 21.223(a)(2) |
| 108-3B | Instruction on Alter Ego in Cases Not Governed by Tex. Bus. Orgs. Code § 21.223(a)(2) |
| 108-3 addl instr corporate formalities | |
| 108-4 | Instruction on Sham to Perpetrate a Fraud |
| 108-4A | Instruction on Sham to Perpetrate a Fraud in Cases Governed by Tex. Bus. Orgs. Code § 21.223(a)(2) |
| 108-4B | Instruction on Sham to Perpetrate a Fraud in Cases Not Governed by Tex. Bus. Orgs. Code § 21.223(a)(2) |
| 108-5 | Instruction on Evasion of Existing Legal Obligation |
| 108-5A | Instruction on Evasion of Existing Legal Obligation in Cases Governed by Tex. Bus. Orgs. Code § 21.223(a)(2) |
| 108-5B | Instruction on Evasion of Existing Legal Obligation in Cases Not Governed by Tex. Bus. Orgs. Code § 21.223(a)(2) |
| 108-6 | Instruction on Circumvention of a Statute |
| 108-6A | Instruction on Circumvention of a Statute in Cases Governed by Tex. Bus. Orgs. Code § 21.223(a)(2) |
| 108-6B | Instruction on Circumvention of a Statute in Cases Not Governed by Tex. Bus. Orgs. Code § 21.223(a)(2) |
| 108-7 | Instruction on Protection of Crime or Justification of Wrong |
| 108-7A | Instruction on Protection of Crime or Justification of Wrong in Cases Governed by Tex. Bus. Orgs. Code § 21.223(a)(2) |
| 108-7B | Instruction on Protection of Crime or Justification of Wrong in Cases Not Governed by Tex. Bus. Orgs. Code § 21.223(a)(2) |
| 108-8 | Instruction on Monopoly |
| 108-8A | Instruction on Monopoly in Cases Governed by Tex. Bus. Orgs. Code § 21.223(a)(2) |
| 108-8B | Instruction on Monopoly in Cases Not Governed by Tex. Bus. Orgs. Code § 21.223(a)(2) |
Chapter 109 Civil Conspiracy
| 109-1 | Question and Instruction on Conspiracy |
Chapter 110 Defamation, Business Disparagement, and Invasion of Privacy
| 110-1 | Libel and Slander (Comment on Broad Form) |
| 110-2 | Question and Instruction on Publication |
| 110-3 | Question and Instructions on Defamatory Nature of the Publication |
| 110-3 alt Q no publication dispute | |
| 110-4 | Question and Instruction on Falsity |
| 110-4 addl instr false impression | |
| 110-5 | Question and Instruction on Negligence |
| 110-5 alt Q satire or parody | |
| 110-6 | Question and Instructions on Actual Malice |
| 110-6 alt Q satire or parody | |
| 110-7 | Actual Malice in Cases of Qualified Privilege (Comment) |
| 110-8 | Question and Instructions on Defense of Truth |
| 110-8 addl instr false impression | |
| 110-9 | Judicial-Proceedings Privilege and Attorney Immunity (Comment) |
| [PJC 110.10–110.14 are reserved for expansion.] | |
| 110-15 | Question and Instructions on Business Disparagement |
| 110-16 | Question and Instruction on Intrusion |
| 110-17 | Question and Instruction on Publication of Private Facts |
| 110-17 alt Q public concern | |
| 110-17 addl instr matter | |
| 110-18 | Question and Instruction on Invasion of Privacy by Misappropriation |
| 110-19 | False Light Invasion of Privacy (Comment) |
| 110-20 | Defamation Mitigation Act (Comment) |
Chapter 111 Misappropriation of Trade Secrets
| 111-1 | Question and Instructions on Existence of Trade Secret |
| 111-1 alt Q broad form | |
| 111-1 sample instrs | |
| 111-1 def reverse engineer | |
| 111-2 | Question and Instructions on Trade-Secret Misappropriation |
| 111-2 addl instr use | |
| 111-2 addl Q date | |
| 111-2 addl instr former employee |
[Chapters 112–114 are reserved for expansion.]
Chapter 115 Damages
| 115-1 | Predicate—Instruction Conditioning Damages Questions on Liability |
| [PJC [number]–[number] [is/are] reserved for expansion.] | |
| 115-2 | Instruction on Whether Compensatory Damages Are Subject to Income Taxes (Actions Filed on or after September 1, 2003) |
| 115-3 | Question on Contract Damages |
| 115-3 addl instr sep theories | |
| 115-3 alt instr sep elements | |
| 115-3 alt Q insurance | |
| 115-4 | Sample Instructions on Direct and Incidental Damages—Contracts |
| 115-4 addl sample instrs | |
| 115-5 | Instructions on Consequential Damages—Contracts |
| 115-6 | Question on Promissory Estoppel—Reliance Damages |
| 115-6 alt instr sep elements | |
| 115-7 | Question on Quantum Meruit Recovery |
| 115-8 | Defensive Instruction on Mitigation—Contract Damages |
| 115-9 | Question and Instruction on Deceptive Trade Practice Damages |
| 115-9 alt instr sep elements | |
| 115-10 | Sample Instructions—Deceptive Trade Practice Damages |
| 115-11 | Question on Additional Damages—Deceptive Trade Practices |
| [PJC [number]–[number] [is/are] reserved for expansion.] | |
| 115-12 | Contribution—Deceptive Trade Practices Act and Insurance Code Chapter 541 (Comment) |
| 115-13 | Question and Instruction on Actual Damages under Insurance Code Chapter 541 |
| 115-13 alt instr sep elements | |
| 115-14 | Question and Instruction on Actual Damages for Breach of Duty of Good Faith and Fair Dealing |
| 115-15 | Remedies for Breach of Fiduciary Duty (Comment) |
| 115-16 | Question on Profit Disgorgement—Amount of Profit |
| 115-17 | Question on Fee Forfeiture—Amount of Fee |
| 115-18 | Question on Actual Damages for Breach of Fiduciary Duty |
| 115-18 alt instr sep elements | |
| 115-19 | Question and Instruction on Direct Damages Resulting from Fraud |
| 115-19 alt instr sep elements | |
| 115-20 | Question and Instruction on Consequential Damages Caused by Fraud |
| 115-20 alt instr sep elements | |
| 115-21 | Question and Instruction on Monetary Loss Caused by Negligent Misrepresentation |
| 115-21 alt instr sep elements | |
| 115-21 addl instr sep theories | |
| 115-22 | Question on Damages for Intentional Interference with Existing Contract or for Wrongful Interference with Prospective Contractual Relations |
| 115-22 alt instr sep elements | |
| 115-22 addl instr sep theories | |
| [PJC 115.23 is reserved for expansion.] | |
| 115-24 | Sample Instructions on Direct and Incidental Damages—Breach of Employment Agreement |
| 115-25 | Defensive Instruction on Mitigation—Breach of Employment Agreement Damages |
| 115-26 | Question and Instruction on Damages for Wrongful Discharge for Refusing to Perform an Illegal Act |
| 115-26 alt instr sep elements | |
| 115-27 | Question and Instructions on Damages for Retaliation under Texas Whistleblower Act |
| 115-27 alt instr sep elements | |
| 115-28 | Question and Instruction on Damages—Retaliation for Seeking Workers’ Compensation Benefits |
| 115-28 alt instr sep elements | |
| [PJC 115.29 is reserved for expansion.] | |
| 115-30 | Question and Instruction on Unlawful Employment Practices Damages |
| 115-30 alt instr sep elements | |
| 115-31 | Predicate Question and Instruction on Exemplary Damages for Unlawful Employment Practices |
| 115-31 alt instr multiple defendants | |
| 115-32 | Question on Employer Liability for Exemplary Damages for Conduct of Supervisor |
| 115-33 | Question and Instructions—Defamation General Damages |
| 115-33 alt instr nominal damages | |
| 115-33 alt instr sep elements | |
| 115-34 | Question and Instructions—Defamation Special Damages |
| 115-34 alt instr sep elements | |
| 115-35 | Question and Instructions—Invasion of Privacy Damages |
| 115-35 alt instr sep elements | |
| 115-36 | Proportionate Responsibility |
| 115-36 alt answers addl responsible | |
| 115-36 alt Q comparative | |
| 115-37 | Predicate Question and Instruction on Award of Exemplary Damages |
| 115-37A | Question and Instruction for Actions Filed before September 1, 2003 |
| 115-37B | Question and Instruction for Actions Filed on or after September 1, 2003 |
| 115-37 alt Q fraud | |
| 115-37 addl instr gross neg | |
| 115-37 alt instr multiple defendants | |
| 115-38 | Question and Instruction on Exemplary Damages |
| 115-38 alt instr pre-2003 | |
| 115-38 alt instr multiple defendants | |
| 115-39 | Question and Instruction for Imputing Liability for Exemplary Damages |
| 115-39A | Question and Instruction Imputing Malice to a Corporation—Causes of Action Accruing on or after September 1, 1995, and Filed before September 1, 2003 |
| 115-39B | Question and Instruction Imputing Gross Negligence to a Corporation—Actions Filed on or after September 1, 2003 |
| 115-40 | Question and Instructions—Fraudulent Securing of Document Execution as a Statutory Ground for Removing Limitation on Exemplary Damages (Tex. Civ. Prac. & Rem. Code § 41.008(c)(11)) |
| 115-40 alt def 1 intentionally | |
| 115-40 alt def 2 intentionally | |
| 115-40 alt def service | |
| 115-40 alt def effective consent | |
| 115-41 | Question and Instructions—Fraudulent Destruction, Removal, or Concealment of Writing as a Statutory Ground for Removing Limitation on Exemplary Damages (Tex. Civ. Prac. & Rem. Code § 41.008(c)(12)) |
| 115-41 alt def 1 intentionally | |
| 115-41 alt def 2 intentionally | |
| 115-42 | Question and Instructions—Forgery as a Statutory Ground for Removing Limitation on Exemplary Damages (Tex. Civ. Prac. & Rem. Code § 41.008(c)(8)) |
| 115-42 alt def 1 intentionally | |
| 115-42 alt def 2 intentionally | |
| 115-43 | Question and Instructions—Theft as a Statutory Ground for Removing Limitation on Exemplary Damages (Tex. Civ. Prac. & Rem. Code § 41.008(c)(13)) |
| 115-43 alt def 1 intentionally | |
| 115-43 alt def 2 intentionally | |
| 115-43 alt instrs consent | |
| 115-44 | Question and Instructions—Commercial Bribery as a Statutory Ground for Removing Limitation on Exemplary Damages (Tex. Civ. Prac. & Rem. Code § 41.008(c)(9)) |
| 115-44 alt def 1 knowingly intentionally | |
| 115-44 alt def 2 knowingly intentionally | |
| 115-44 addl def consent | |
| 115-44 addl def benefit | |
| 115-44 alt Q bribery | |
| 115-45 | Question and Instructions—Misapplication of Fiduciary Property or Property of Financial Institution as a Statutory Ground for Removing Limitation on Exemplary Damages (Tex. Civ. Prac. & Rem. Code § 41.008(c)(10)) |
| 115-45 alt def 1 knowingly intentionally | |
| 115-45 alt def 2 knowingly intentionally | |
| 115-45 addl def agreement | |
| 115-45 alt Q financial institution | |
| 115-46 | Other Conduct of Defendant Authorizing Removal of Limitation on Exemplary Damages Award (Comment) |
| [PJC 115.47 is reserved for expansion.] | |
| 115-48 | Question and Instruction on Damages for Misapplication of Trust Funds under the Texas Construction Trust Funds Act |
| 115-48 addl instr excuse | |
| 115-49 | Question and Instructions on Prompt Payment to Contractors and Subcontractors Damages |
| [PJC 115.50–115.53 are reserved for expansion.] | |
| 115-54 | Question on Trade-Secret Misappropriation Damages |
| 115-54 alt instr sep elements | |
| 115-55 | Sample Instructions on Actual Damages—Trade-Secret Misappropriation |
| 115-55 addl sample hypo sale | |
| [PJC 115.56–115.59 are reserved for expansion.] | |
| 115-60 | Question on Attorney’s Fees |
| 115-60 addl instr reasonable fee | |
| 115-60 alt instr predicate | |
| 115-60 addl instr zero fees |
Chapter 116 Preservation of Charge Error
| 116-1 | Preservation of Charge Error (Comment) |
| 116-2 | Broad-Form Issues and the Casteel Doctrine (Comment) |