What Are New York Pattern Jury Instructions (PJI)?

New York Pattern Jury Instructions are the New York Pattern Jury Instructions—Civil (PJI), a set of model civil jury charges prepared by the Committee on Pattern Jury Instructions of the Association of Supreme Court Justices of the State of New York. The PJI is highly influential and widely used, but it is persuasive rather than legally mandatory.

This article explains what the PJI is, who prepares and updates it, why it is authoritative without being binding and how New York litigators use it in personal injury trials. Because the set is revised regularly, counsel should confirm the current edition before drafting a proposed charge.

What Is the PJI and What Does It Contain?

The PJI is New York’s leading set of model civil jury instructions, providing standardized language that trial judges commonly use to charge juries in civil cases. Each pattern charge states the governing rule in language meant for lay jurors and is accompanied by an extensive “Comment” that collects the statutes and appellate decisions supporting the instruction. Those comments are among the most heavily cited secondary authorities in New York civil practice, valued as much for their research as for the charge language itself.

The set spans the full range of civil litigation, from general negligence and causation to premises liability, medical malpractice, products liability and damages. Its numbering system — for example, the 2:10 series for common-law negligence — lets counsel and courts locate a charge quickly and refer to it precisely.

• Each PJI charge pairs jury-ready language with a detailed comment citing supporting authority.
• The comments function as a respected treatise on New York substantive law, not merely a drafting aid.
• Coverage includes negligence, premises liability, medical malpractice, products liability and damages.
• The numbering system allows precise citation to a specific pattern charge.

Who Prepares and Updates the New York PJI?

The PJI is prepared and maintained by the Committee on Pattern Jury Instructions of the Association of Supreme Court Justices of the State of New York, a body of sitting and former trial judges. The committee drafts the charges and comments, monitors legislative changes and appellate developments and revises the set to keep it current. The instructions are published in book and electronic form and are updated on a recurring basis, including annual supplementation.

Because the drafters are experienced trial judges rather than a legislative body, the PJI carries professional credibility without carrying the force of a court rule. Revisions can add new charges, refine existing language and update the comments as the case law evolves, so the edition in effect at the time of trial is the one that matters.

• The committee is composed of experienced New York trial judges.
• The set is revised and supplemented on a regular schedule to track new law.
• Updated comments capture recent appellate decisions and statutory changes.
• The current edition governs, so counsel should cite the latest release.

Are the PJI Instructions Mandatory in New York?

The PJI instructions are persuasive rather than mandatory, meaning New York trial judges are not legally required to give a pattern charge verbatim. A court may modify a PJI charge, or decline to use one, so long as the instruction it does give correctly states the law and fairly presents the issues to the jury. This is a materially different status from California’s CACI instructions, which trial courts are directed to use unless a different instruction would more accurately state the law.

In practice, however, the PJI’s persuasive status understates its influence. Because the charges are drafted by judges and closely tracked to controlling authority, courts use them routinely, and a party seeking a departure typically must show why the pattern language is wrong or ill-fitting. A charge that follows an accurate PJI instruction is rarely reversible on the language alone, while an off-pattern instruction invites closer scrutiny.

• New York courts are not required to deliver PJI charges word for word.
• A modified or non-pattern charge is permissible if it correctly states the law.
• Despite its persuasive status, the PJI is used routinely and departures draw scrutiny.
• Following an accurate pattern charge reduces the risk of reversible instructional error.

How Do Lawyers Use the PJI in Personal Injury Cases?

Lawyers use the PJI throughout a personal injury case to define the elements of each claim, guide discovery and draft the requests to charge submitted at trial. Early on, counsel work backward from the applicable negligence and damages charges to identify what the proof must establish, then use the comments to research the governing standard and anticipate disputes. At the charge conference, the parties submit proposed PJI-based instructions, argue over which charges apply and how they should be tailored and preserve objections for appeal.

The PJI matters in injury litigation because it supplies the shared vocabulary courts and counsel use to frame liability and damages, from comparative negligence apportionment to the categories of noneconomic loss a jury may award. Its comments also serve as a first stop for legal research, making the set useful long before trial. For a broader look at how pattern charges operate nationally, see the jury instructions hub.

1. Identify the PJI charges that correspond to each claim and defense.
2. Use the charge elements and comments to shape discovery and research the controlling law.
3. Submit requests to charge and negotiate the applicable pattern language and any modifications.
4. Anchor summation to the language the jury will hear, and preserve objections to any charge believed to misstate the law.

Conclusion

The New York Pattern Jury Instructions—Civil are the state’s leading model civil charges, prepared by a committee of New York Supreme Court justices and updated on a recurring schedule. The PJI is persuasive rather than mandatory, yet its judicial authorship and richly annotated comments give it practical authority that few sets can match. For New York injury litigators, the PJI is both a drafting resource and a research treatise, and confirming the current edition remains a routine but important step before any charge conference.

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