CACI VF-2400 Breach of Employment Contract—Unspecified Term

California Civil Jury Instructions CACI

VF-2400 Breach of Employment Contract—Unspecified Term


We answer the questions submitted to us as follows:

1.Did [name of plaintiff] and [name of defendant] enter into an employment relationship?

 Yes   No

If your answer to question 1 is yes, then answer question 2. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form.

2.Did [name of defendant] promise, by words or conduct, not to [discharge/demote] [name of plaintiff] except for good cause?

 Yes   No

If your answer to question 2 is yes, then answer question 3. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form.

3.Did [name of plaintiff] substantially perform [his/her/nonbinary pronoun] job duties?

 Yes   No

If your answer to question 3 is yes, skip question 4 and answer question 5. If you answered no, answer question 4.

4.Was [name of plaintiff]’s performance excused or prevented?

 Yes   No

If your answer to question 4 is yes, then answer question 5. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form.

5.Did [name of defendant] [discharge/demote] [name of plaintiff] without good cause?

 Yes   No

If your answer to question 5 is yes, then answer question 6. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form.

6.Was [name of plaintiff] harmed by the [discharge/demotion]?

 Yes   No

If your answer to question 6 is yes, then answer question 7. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form.

7.What are [name of plaintiff]’s damages?

[a.Past economic loss: $]

[b.Future economic loss: $]

TOTAL $

Signed:Presiding Juror
Dated: 

After [this verdict form has/all verdict forms have] been signed, notify the [clerk/bailiff/court attendant] that you are ready to present your verdict in the courtroom.


Directions for Use

The special verdict forms in this section are intended only as models. They may need to be modified depending on the facts of the case. This verdict form is based on CACI No. 2401, Breach of Employment Contract—Unspecified Term—Essential Factual Elements.

Questions 3 and 4 should be deleted if substantial performance is not at issue.

The breakdown of damages is optional; depending on the circumstances, users may wish to break down the damages even further.

If there are multiple causes of action, users may wish to combine the individual forms into one form. If different damages are recoverable on different causes of action, replace the damages tables in all of the verdict forms with CACI No. VF-3920, Damages on Multiple Legal Theories.