Jury Instructions for
Contract Cases

A comprehensive treatise on pattern jury instructions and the theory and technique for charging the jury in actions for breach of contract.

By Robert E. Kehoe, Jr.
(Chicago, Illinois)

Never again will trial lawyers have to search for help to prepare jury instructions for contract cases. With nearly 1000 pattern jury instructions and more than 2500 case citations, this new treatise provides expert guidance for drafting the most effective and appropriate instructions possible.

Volume 1 sets forth dozens of master contract jury instructions that capture the best thinking of hundreds of other pattern instructions and nearly countless court decisions in the field. Each instruction is extensively annotated to explain how to use it to maximum effect -- backed up by appellate cases that not only substantiate the point of law in question but also evaluate the sufficiency and validity of instructions actually used at trial.

Each commentary also includes a comparative analysis of how the same topic has been covered in many other current pattern instructions, with the texts of such instructions immediately presented for convenient reference. No existing work on jury instructions offers such a wealth of information, compiled in a form that is so easy to use.

Volume 2 takes the reader through the most in-depth study of contract instructions ever conducted, reprinting verbatim more than 900 official pattern jury instructions on contract topics. The author's comprehensive analysis of "Theory and Technique" traces in elaborate detail the development of the standardized contract instructions currently in vogue and points out their strengths and weaknesses for today's jury trials. No serious advocate will dare to be unfamiliar with the subtle and sophisticated issues that lurk within the challenge of properly educating the jury on the law and issues of a contract trial.