31.15 [1992 New] Verdict Directing-Inherently Dangerous Activity-Liability of Employer of Independent Contractor

Instruction No 1 31.15 [1992 New] Verdict Directing--Inherently Dangerous Activity-- Liability of Employer of Independent Contractor Your verdict must be for plaintiff and against (state the name of the employer of the independent contractor ) if you believe: First, (here describe the allegedly inherently dangerous activity ) was an inherently dangerous activity, and Second, during such activity, (state the name of independent contractor ) either: failed to (here state the special precaution the independent contractor failed to take ), or failed to (here insert alternative failure ), and Third, (state the name of independent contractor ), in one or more of the respects submitted in Paragraph Second, was thereby negligent, and Fourth, such negligence and the danger inherent in such activity combined to directly cause damage to plaintiff. * [unless you believe plaintiff is not entitled to recover by reason of Instruction Number (here insert number of affirmative defense instruction ) ].