Can instructions be submitted electronically?

Many Iowa courts accept electronic filing of proposed instructions; verify the court’s e-filing guidelines and filename requirements before submission.

When must proposed instructions be served?

Service deadlines are set by the scheduling order or local rule; missing the deadline can limit your ability to challenge or present instructions at the conference.

How should disputed language be presented?

Propose alternatives with bracketed text and provide a concise legal memorandum explaining the dispute and supporting authority for the judge’s review.

Are verdict forms required?

Providing draft verdict forms aligned with instructions helps avoid inconsistent jury findings and clarifies the issues that jurors must decide.

What happens at the charge conference?

The judge and counsel discuss proposed instructions, resolve objections, and decide which instructions will be given and in what wording.

Can electronic signatures be used on submissions?

Electronic signatures are widely accepted under federal and state e-signature laws, but follow court local rules and include a complete audit trail for authenticity.

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Iowa Civil Jury Instructions

Iowa Civil Jury Instructions

This template is fully customizable. Edit the text, fill out the fields, and send it for signature. Give it a try!

MPI 9.27 Intentional Torts - Defamation - Damages

If you find that the defendant defamed plaintiff and that such defamation caused damage to plaintiff, you may award plaintiff compensation for any losses suffered to date and which are reasonably probable to occur in the future in respect to plaintiff's property, business, trade, profession, or occupation including the amount of actual damage which is a natural consequence of the publication of the defamation.

You may also consider, but are not limited to the following:

(1) The extent of the publicity given by the defendant to the defamation;

(2) Plaintiff's good name, reputation, and the loss thereof;

(3) Plaintiff's shame, mortification, injured feelings and mental suffering;

[(4) Plaintiff's standing in the community.]

[(5) Plaintiff's standing in the business or professional community.]

In determining the amount of plaintiff's damage, the law does not establish any absolute standard by which to compute such damage; therefore, you may exercise your discretion but must do so without passion or prejudice for or against either party.

[Furthermore, such damages shall not be enhanced by a repetition of such [libel] [slander] by third persons who are not parties to this action unless such repetition was authorized or intended or could have been reasonably foreseen.]

What the Iowa Civil Jury Instructions Are

The Iowa Civil Jury Instructions are standardized, court-approved statements of law intended for use in civil trials in Iowa. They provide jurors with clear legal definitions, elements of claims and defenses, and guidance on the law to apply when deciding facts. Judges and attorneys use these instructions to craft the final charge the jury receives. While many instructions are form-based, they may be adapted to the facts of a case; proposed modifications must remain consistent with Iowa precedent and local rules to avoid confusing the jury or creating grounds for appeal.

Why These Instructions Matter in Civil Trials

Accurate jury instructions shape the legal framework jurors use to decide a case. Clear instructions reduce appellate risk, focus deliberations, and ensure parties understand required elements and burdens of proof. Using the approved Iowa Civil Jury Instructions promotes consistency across cases and helps align trial presentation with established legal standards.

Primary Users and Stakeholders

Other participants include mediators, appellate counsel, and legal researchers who reference the instructions during and after trial.

Trial Judges and Chambers staff who draft and adopt the final charge for the jury.
Plaintiffs' and defense counsel who prepare proposed instructions and objections.
Court Clerks and court reporters who manage filing, distribution, and recordkeeping.

Core Parts of a Professional Instruction Set

A well-organized packet of Iowa Civil Jury Instructions includes numbered instruction text, case-specific adaptions, citation sources, verdict forms, and a cover memorandum explaining proposed changes to the standard text.

Numbering

Sequential instruction numbers that reference the Iowa-approved set and make cross-referencing within the charge straightforward and unambiguous for jurors.

Plain Text

Clear, neutral language stating legal elements, burdens of proof, and definitions without argument, tailored narrowly to the facts at issue.

Citation

Short citation notes indicating the authority or case law supporting each instruction, provided for the judge and the appellate record.

Modifications

Trackable edits or bracketed additions showing only the language necessary to fit the case facts while preserving statutory or precedent-based meaning.

Verdict Forms

Draft special verdict questions or general verdict forms that align with instructive elements and permit clear jury findings on each disputed issue.

Cover Memo

A concise explanation of proposed changes, contested instructions, and the party’s legal rationale to assist judicial review.

Essential Information to Include

Case Caption: Plaintiff v. Defendant

Court Name: County and judicial district

Instruction Number: Sequential identifier

Instruction Text: Complete, edited language

Proponent: Party proposing instruction

Citation: Supporting authority

Step-by-Step: Preparing Proposed Jury Instructions

Follow this sequence to prepare instructions that are admissible and usable at trial.

01

Review Standard Set: Compare the case facts to Iowa-approved instructions.
02

Draft Changes: Edit only necessary language for the case.
03

Prepare Memo: Explain legal support and contested points.
04

File and Serve: Submit per local rule and serve opposing counsel.

How to Customize and Submit Instructions Online

Many courts accept electronic submissions; configure workflow to match court e-filing and local formatting requirements.

Field	Configuration
Document Format	PDF/A preferred for static text
Filename Convention	Use docket number and short title
Cover Memo	Attach as separate document
Service Method	E-service or email per local rule

Where to File and How Submissions Move Through the Court

Understand the destination and routing so filings are accepted and included in the trial record.

E-Filing Portal: Upload to the court’s electronic filing system
Clerk Review: Clerk checks compliance and docketing
Judge Consideration: Judge reviews and may edit instructions
Entry on Record: Final charge entered before jury deliberations

Technical Considerations for Electronic Submission

Also ensure your workflow preserves the audit trail and that served copies are sent to opposing counsel in the format required by local rules.

Accepted File Types: PDF, DOCX
Maximum File Size: Varies by portal
Accessibility: Follow plain-text or tagged PDF guidance

Common Deadlines and Timing Expectations

Courts set filing deadlines by local rule or scheduling order; check the trial notice or pretrial order for exact dates.

Proposed Instructions Deadline:

Often 7–14 days before trial

Objections Deadline:

Typically within days after service

Request for Oral Argument:

Follow judge’s local procedure

Final Charge Deadline:

Before jury instructions conference

Post-Trial Additions:

Limited and subject to court approval

Key Milestones in the Instruction Process

The following stages are sequential milestones from drafting to the final jury charge.

01

Draft Submission

Prepare proposed instructions and cover memo

02

Service to Opposing Counsel

Serve proposals and supporting authority

03

Court Review and Conference

Judge resolves disputes at instruction conference

04

Final Charge Delivery

Judge reads the final instructions to the jury

Common Pitfalls to Avoid

Submitting instructions with embedded tracked changes or comments that the clerk cannot process.
Proposing argumentative language that blends advocacy into an instruction rather than stating neutral law.
Omitting verdict forms or failing to align verdict questions with instruction elements.
Missing the local filing deadline for proposed instructions, which can forfeit objections or proposed language.

Consequences of Improper Instructions

Waiver Risk: Preservation of issues may be lost

Reversal Risk: Appellate reversal possible

Mistrial: Serious errors may lead to mistrial

Delay: Trial schedule disruption

Sanctions: Procedural sanctions in extreme cases

Jury Confusion: Poorly worded law misleads jurors

eSignature Vendor Comparison for Filing and Signing Documents

For preparing, signing, and exchanging proposed instructions electronically, signNow and other platforms offer varying feature sets and price points.

	signNow	DocuSign	Adobe Sign	PandaDoc	HelloSign
Starting Price	$8/user/mo	$15/user/mo	$14/user/mo	$19/user/mo	$15/user/mo
Free Trial	7-day free trial	Varies	Varies	Varies	Varies
Bulk Send	Yes	Yes	Yes	Yes	No
Audit Trail	Yes	Yes	Yes	Yes	Yes
HIPAA Compliant	Yes	Yes	Yes	No	No

Frequently Asked Questions About Iowa Civil Jury Instructions

Answers to common questions about drafting, filing, objections, and electronic submission of proposed jury instructions in Iowa civil cases.

Need help? Contact support

Can instructions be submitted electronically?
Many Iowa courts accept electronic filing of proposed instructions; verify the court’s e-filing guidelines and filename requirements before submission.
When must proposed instructions be served?
Service deadlines are set by the scheduling order or local rule; missing the deadline can limit your ability to challenge or present instructions at the conference.
How should disputed language be presented?
Propose alternatives with bracketed text and provide a concise legal memorandum explaining the dispute and supporting authority for the judge’s review.
Are verdict forms required?
Providing draft verdict forms aligned with instructions helps avoid inconsistent jury findings and clarifies the issues that jurors must decide.
What happens at the charge conference?
The judge and counsel discuss proposed instructions, resolve objections, and decide which instructions will be given and in what wording.
Can electronic signatures be used on submissions?
Electronic signatures are widely accepted under federal and state e-signature laws, but follow court local rules and include a complete audit trail for authenticity.

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