Does anyone have a state court jury charge and/or instructions on tort claims - use of tangible property - and/or Section 1983 case. If so, please respond so that I can get info from you. We have federal court jury charge on Section 1983, but no state court charge. We are trying a case involving a death in the El Paso county jail.

I would love to help out, but the second we sniff a section 1983 component to a lawsuit, we remove immediately. Thus, we don't have any state court 1983 charge forms. Most of our jail deaths wind up as 1983 cases, anyway. We had a suicide last year that was tentatively thrown at us as a Tort Claims Act case, but the real claim would have been defective design and failure to prevent use of a towel (neither of which invoke the act or its waiver).

This inquiry points up a more basic need for a go-to source for good charge forms, though. Sometimes, the PJCs and the Fifth Circuit forms don't fill every need.