A Missouri Instruction to Jury is a set of guidelines provided to jurors to help them understand the legal principles involved in a specific case. In the context of refusal to deliver goods after demand and tender of freight and storage charges, jury instructions in Missouri explain how such actions can potentially amount to conversion. Conversion refers to the wrongful exercise of control over someone else's property, depriving the owner of their rights to use and possess it. When a party refuses to deliver goods even after a valid demand and the tender of applicable charges for freight and storage, it may be considered conversion under certain circumstances. Here are a few types of Missouri Jury Instructions that deal with this specific situation: 1. Instruction on the Elements of Conversion: This instruction outlines the essential elements that must be proven to establish a claim of conversion. It may include elements such as the plaintiff's ownership or right to possession of the goods, the defendant's wrongful exercise of control over the goods, and the resultant damages suffered by the plaintiff. 2. Instruction on Demand and Tender of Freight and Storage Charges: This instruction explains the requirement for the plaintiff to have made a lawful demand for the goods and properly tendered the necessary charges for freight and storage. It may also provide guidance on what constitutes a valid demand and the acceptable methods of tendering payment. 3. Instruction on Refusal to Deliver Goods: This instruction focuses specifically on the actions taken by the defendant, emphasizing that their refusal to deliver the goods, despite a valid demand and tender of freight and storage charges, can be considered conversion. It may highlight how the defendant's failure to comply with the lawful request can lead to the deprivation of the plaintiff's possession rights and any resulting harm or damages. 4. Instruction on Intent in Conversion Claims: This instruction delves into the element of intent required to establish a claim of conversion. It may explain that the defendant's refusal to deliver the goods, knowing that they have been validly demanded and paid for, can be seen as an intentional act, which reinforces the claim of conversion. By using these Missouri Jury Instructions, jurors can better comprehend the legal principles involved in cases where refusal to deliver goods after demand and tender of freight and storage charges is alleged. These instructions help guide jurors in assessing the merits of the claim and determining whether the actions of the defendant amount to conversion, ultimately aiding in the fair and just resolution of the case.