District of Columbia Instruction to Jury on Conversion for Refusal to Deliver Goods after Demand and Tender of Freight and Storage Charges: In the District of Columbia, when a party fails to deliver goods after a lawful demand and tender of freight and storage charges, it may legally constitute "conversion." Conversion refers to the unauthorized and wrongful interference with another person's property rights, leading to the substantial deprivation of the owner's enjoyment or possession of the property. This instruction to the jury outlines the legal principles and elements that need to be considered when determining whether such refusal to deliver goods can be categorized as conversion. It is important to note that multiple types of instructions may be given based on the specific circumstances of the case. Some possible types of instructions in the District of Columbia include: 1. Instruction on the Elements of Conversion: This type of instruction provides a detailed explanation of the essential elements required to establish a claim for conversion based on refusal to deliver goods after demand and tender of freight and storage charges. These elements usually include the plaintiff's ownership or right to possess the goods, defendant's refusal to deliver the goods despite a lawful demand, and damages suffered by the plaintiff due to the refusal. 2. Instruction on Lawful Demand and Tender: This instruction addresses what constitutes a proper demand for delivery and tender of freight and storage charges. It may explain that a demand should be clear, specific, and in accordance with any applicable contractual terms or obligations. It may also highlight that the plaintiff must prove the lawful tender of freight and storage charges to the defendant. 3. Instruction on Consequences of Refusal: This type of instruction clarifies that if the jury finds that the defendant unreasonably or wrongfully refused to deliver the goods after a proper demand and tender, they may consider such refusal as an act of conversion. It may emphasize that conversion is a serious legal wrong and may entitle the plaintiff to various forms of damages or other appropriate remedies. 4. Instruction on Defenses: This instruction explains any applicable defenses that the defendant may raise to excuse or justify their refusal to deliver the goods. Potential defenses may include disputes over ownership, claims of non-payment, disputes regarding the terms of the contract, or any lawful excuse that justifies the refusal. 5. Instruction on Damages: In cases where the jury finds in favor of the plaintiff, this instruction outlines the types of damages that may be awarded. It may include compensatory damages, which aim to restore the plaintiff to the position they were in before the conversion, as well as potential punitive damages if the defendant's conduct was particularly willful, wanton, or malicious. These are general categories of District of Columbia instructions that may be relevant in cases involving the refusal to deliver goods after demand and tender of freight and storage charges, constituting conversion. However, it is important to consult the District of Columbia's specific laws and legal precedents to ensure the accuracy and precision of the instructions given in a particular case.