Florida Instruction to Jury that Refusal to Deliver Goods after Demand and Tender of Freight and Storage Charges can Constitute Conversion: Conversion is a legal term used to describe an act where someone wrongfully exercises unauthorized control over another person's property, depriving the rightful owner of their possession or use. In the context of refusing to deliver goods after demand and tender of freight and storage charges, such refusal can be considered a form of conversion. In the state of Florida, there are various types of instructions that a jury may receive when determining whether the defendant's actions constitute conversion in this specific scenario. These instructions include: 1. Standard Florida Instruction to Jury for Conversion: This instruction informs the jury about the general principles of conversion and its elements. It explains that unauthorized control over the goods, depriving the owner of their possession, can constitute conversion. 2. Florida Instruction to Jury for Conversion in Cases of Refusal to Deliver Goods: This instruction specifically addresses the situation where the defendant refuses to deliver goods after a demand has been made and the freight and storage charges have been tendered. It guides the jury in assessing whether the defendant's refusal amounts to unauthorized control and a deprivation of the owner's right to possession. 3. Instruction on Tender of Freight and Storage Charges: This instruction emphasizes the importance of tendering the proper freight and storage charges. It explains that the rightful owner must fulfill their obligation to pay the appropriate fees and charges before making a demand for delivery. Failure to tender these charges could impact the determination of whether conversion has occurred. 4. Florida Instruction on Damages in Conversion Cases: This instruction provides guidance to the jury when determining the appropriate damages to be awarded in a conversion case. It outlines the different types of damages that can be sought, including compensatory damages to cover the value of the converted goods, consequential damages, and potentially punitive damages if the defendant's conduct was particularly egregious. These are some examples of the different types of Florida instructions to the jury that can address the issue of refusal to deliver goods after demand and tender of freight and storage charges constituting conversion. It is essential for the jury to carefully consider these instructions and evaluate the evidence presented in order to reach a fair and just determination in the case.