VF-409 . Dog Bite Statute (Civ . Code, § 3342)
W e answer the questions submitted to us as follows:
1. Did [ name of defendant ]’s dog bite [ name of plaintiff ]?
1. 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. Was [ name of plaintiff ] in a public place or lawfully on private
property when [he/she/ nonbinary pronoun ] was bitten?
2. 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 the dog a substantial factor in causing harm to [ name of
3. 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. What are the damages, if any, that [ name of plaintiff ] suf fered as a
result of the dog bite?
[a. Past economic loss
[lost earnings $ ]
[lost profits $ ]
[medical expenses $ ]
[other past economic loss $ ]
[a. Total Past Economic Damages: $ ]
[b. Future economic loss
[lost earnings $ ]
[lost profits $ ]
[medical expenses $ ]
[other future economic loss $ ]
[b. Total Future Economic Damages: $ ]
[c. Past noneconomic loss, including [physical
pain/mental suf fering:] $ ]
[d. Future noneconomic loss, including [physical
pain/mental suf fering:] $ ]
Signed: Presiding Juror
After [this verdict form has/all verdict forms have] been signed, notify
the [clerk/bailif f/court attendant] that you ar e ready to pr esent your
verdict in the courtroom.
New September 2003; Revised April 2007, December 2010, December 2016
Directions for Use
This verdict form is based on CACI No. 463, Dog Bite Statute (Civ . Code,
§ 3342) - Essential Factual Elements.
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.
If specificity is not required, users do not have to itemize all the damages listed in
question 4. The breakdown is optional depending on the circumstances.
If there are multiple causes of action, users may wish to combine the individual
forms into one form. If dif ferent damages are recoverable on dif ferent causes of
action, replace the damages tables in all of the verdict forms with CACI No. VF-
3920, Damages on Multiple Legal Theories .
If the jury is being given the discretion under Civil Code section 3288 to award
prejudgment interest (see Bullis v . Security Pac. Nat’l Bank (1978) 21 Cal.3d 801,
814 [148 Cal.Rptr . 22, 582 P .2d 109]), give CACI No. 3935, Pr ejudgment Inter est .
This verdict form may need to be augmented for the jury to make any factual
findings that are required in order to calculate the amount of prejudgment interest.
VF-409 NEGLIGENCE
Page last reviewed May 2024
Kathryn Robb, National Director of the Children’s Justice Campaign at Enough Abuse, discusses Vice President Kamala Harris’s unusual mention of child sexual abuse during her Democratic National Convention speech and its broader implications for addressing this issue in America.
Lawyers - Get Listed Now! Get a free directory profile listing
