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Judge Simon: Jury Instructions - Civil

Proposed jury instructions should be filed of record in the docket of the case.

In addition to being filed, proposed jury instructions should also be submitted to the chambers mailbox in Word Perfect or Microsoft Word format, by e-mail to Judge Simon's chambers mailbox.

Parties should only submit jury instructions for issues not covered by this set of boilerplate instructions dealing with standard trial matters:

General Civil Jury Instructions

Where an applicable Seventh Circuit Pattern Instruction exists, Judge Simon is inclined to use it unless a party makes a strong showing of its inappropriateness.


Jury instructions from Judge Simon's prior civil trials are below.


Case Name Type of Claim(s) Trial Year
Dowling v. Amtrak FELA 2003
Buggs v. Buffington Harbor Riverboats, LLC Employment discrimination/retaliation 2003
Smith v. Davis First Amendment 2004
Smith v. Biomet Tortious interference/defamation 2004
Biomet Orthopedics v. Tact Medical Breach of contract 2004
Fain v. Norfolk Southern Railway FELA 2005
Travis v. Vulcan Materials Employment discrimination 2005
Mercer v. South Bend Snowmobilers Club Negligence 2006
Peterson v. Farrakhan Negligence 2006
Hebert v. Gonzalez Fourth Amendment 2010
Bartlett v. NIBCO Retaliation 2011
Swan Lake Holdings v. Yamaha Golf Cart Co. Breach of warranty 2011
Stanley v. Irsa and Beltran Excessive force 2011
Thompson v. Finnegan False arrest 2011
Williams v. State Farm Insurance Co. Breach of contract 2011
Blevins v. Town of Mentone Excessive force 2012
Harnish v. Liberty Farm Equine Reproduction Center Negligence/bailment 2013
Hill v. Truck Accessories Group Employment discrimination 2013
Vukadinovich v. Hanover Community School Corp. Employment discrimination/retaliation/due process 2016
Swoope v. Gary Community School Corp. Employment discrimination/retaliation 2016
Hunt v. School Town of Munster Title IV discrimination/equal protection/negligence 2016