All litigation attorneys in Maryland are probably very familiar with the Maryland Pattern Jury Instructions (“MPJI”). The MPJI published by the Maryland State Bar Association through the efforts of a special MSBA committee comprised of practitioners.
Both the Criminal and Civil MPJI are widely used by judges across the state to give written instructions to juries. The Court of Appeals has repeatedly clarified that the Pattern Jury Instructions have “no official status” and trial courts are not obligated to use or adopted them. Armacost v. Davis (Md.2019) However, the reality is that the MPJI are universally relied on by judges and attorneys alike when instructing juries.
The Maryland Pattern Jury Instructions are intended to provide short, understandable, and accurate statements of certain points of law in Maryland. The original version of the Pattern Jury Instructions was first published back in the 1980s. Since then the MPJI has been periodically revised and republished to reflect significant changes and developments in Maryland law. The most recent revision of the MPJI is the 5th Edition which the MSBA published in the fall of 2017. Among the many changes and revisions in the 5th Edition of the MPJI is a new definition of proximate causation at § 19:10.