Utah Jury Instruction — 4.1 Recovery Of Take-Home Pay is a legal instruction given to the jury in a personal injury case involving the loss of take-home pay. This instruction guides the jury on how to calculate and award compensation to the plaintiff for the financial harm caused by the injury in terms of lost take-home pay. It outlines the factors to consider and the evidence required to establish a claim for recovery of take-home pay. The purpose of Utah Jury Instruction — 4.1 Recovery Of Take-Home Pay is to ensure that the jury understands the significance of lost take-home pay and how it impacts the plaintiff's financial stability. The instruction highlights the importance of evaluating the evidence presented by both parties and determining a reasonable and fair amount of compensation in line with the extent of the injury. Key points covered in this Utah Jury Instruction may include: 1. Definition of Take-Home Pay: The instruction may clarify the meaning of take-home pay, which refers to the net income received by an individual after deductions such as taxes, insurance premiums, and other expenses. 2. Requirement of Causation: The instruction may state that the plaintiff must prove that their injury directly caused the loss of take-home pay. This requires demonstrating a clear link between the injury and the subsequent reduction in earnings. 3. Evidence of Past Lost Take-Home Pay: The instruction may explain what evidence can be presented to support a claim for past lost take-home pay. This may include pay stubs, employment records, tax returns, or expert testimony from an economist. 4. Evidence of Future Lost Take-Home Pay: The instruction may outline the factors to consider when determining the plaintiff's potential future loss of take-home pay. This may include the plaintiff's age, occupation, earning capacity, career expectancy, and any anticipated wage increases. 5. Mitigation of Damages: The instruction may emphasize that the plaintiff has a duty to mitigate their damages by seeking alternative employment or other reasonable means to minimize losses. Failure to mitigate may impact the calculation of compensation. It is important to note that while these general content outlines cover the primary aspects of Utah Jury Instruction — 4.1 Recovery Of Take-Home Pay, specific variations or additional directions may exist based on the particular circumstances of the case or the discretion of the court. It is essential for legal professionals to consult the official Utah Jury Instructions for accurate and up-to-date information.