CACI VF-701 Motor Vehicle Owner Liability—Permissive Use of Vehicle—Affirmative Defense—Use Beyond Scope of Permission

California Civil Jury Instructions CACI

VF-701 Motor Vehicle Owner Liability—Permissive Use of Vehicle—Affirmative Defense—Use Beyond Scope of Permission


We answer the questions submitted to us as follows:

1.Was [name of defendant] an owner of the vehicle at the time of the injury to [name of plaintiff]?

 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], by words or conduct, give permission to [name of driver] to use the vehicle?

 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.Was [name of defendant]’s permission to use the vehicle given for a limited time, place, or purpose?

 Yes   No

If your answer to question 3 is yes, then answer question 4. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form.

4.Did [name of driver]’s use of the vehicle substantially violate the limitations as to time, place, or purpose?

 Yes   No

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

This is for use in conjunction with the general negligence verdict forms involving motor vehicles. The four questions here should be incorporated into the verdict form regarding the underlying case. 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. 720, Motor Vehicle Owner Liability—Permissive Use of Vehicle, and CACI No. 721, Motor Vehicle Owner Liability—Affirmative Defense—Use Beyond Scope of Permission.

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.