Ohio Instruction to Jury Conversion Jury Instructions In Ohio, there are specific instructions given to juries regarding the legal concept of conversion in cases involving the refusal to deliver goods after demand and tender of freight and storage charges. Conversion refers to the unauthorized taking or control of another person's property, which deprives the rightful owner of its use and possession. One type of Ohio instruction to the jury in these cases is the "Refusal to Deliver Goods after Demand and Tender of Freight and Storage Charges" instruction. This instruction outlines the essential elements that need to be proven by the plaintiff to establish a claim of conversion: 1. The plaintiff must show that they are the rightful owner, or have a right to possession, of the goods in question. 2. The plaintiff must establish that they made a demand for the delivery of the goods. 3. The plaintiff must provide evidence of tendering or offering to pay the applicable freight and storage charges. 4. The plaintiff must demonstrate that the defendant, without legal justification, refused to deliver the goods despite the demand and tender of charges. If the jury finds that all of these elements have been proven, then they may conclude that the defendant's actions constituted conversion. In such cases, the jury may be instructed to determine the appropriate monetary damages to award the plaintiff, taking into account any loss of use or possession of the goods. It is important to note that this specific instruction regarding refusal to deliver goods after demand and tender of freight and storage charges is part of a broader set of conversion jury instructions in Ohio. Other types of instructions may cover different factual scenarios related to conversion, such as conversion involving the taking or control of goods without any demand or tender of charges. These jury instructions can be tailored based on the specific circumstances of each case. Overall, the Ohio instruction to the jury on the conversion involving the refusal to deliver goods after demand and tender of freight and storage charges plays a crucial role in guiding juries through the legal principles and elements necessary to determine liability and award damages in these types of cases.