Chicago, Illinois is a vibrant and diverse city located in the heart of the Midwest region of the United States. With a rich history and a wealth of cultural and entertainment opportunities, Chicago draws visitors from around the world. From iconic landmarks such as the Willis Tower and Navy Pier to renowned institutions like the Art Institute of Chicago and the Field Museum, the city offers something for everyone. In the legal context, a crucial instruction to a jury in Chicago, Illinois involves the concept of conversion concerning the refusal to deliver goods after demand and tender of freight and storage charges. Conversion refers to an act where a person unlawfully interferes with another's personal property, thereby depriving them of their rightful possession. When it comes to the refusal of delivery of goods along with the demand for payment of freight and storage charges, this can potentially constitute an act of conversion. The instruction to the jury plays a key role in guiding them to determine whether the refusal to deliver goods after the rightful demand and tender of freight and storage charges can be considered an act of conversion. The instruction should emphasize the following key points: 1. Explanation of Conversion: The instruction should define conversion and explain that it entails the intentional interference with another person's property rights, resulting in deprivation of possession. 2. Demand for Delivery: The instruction should clarify that the plaintiff had appropriately demanded the delivery of the goods, which establishes their right to possess them. 3. Tender of Freight and Storage Charges: The instruction should emphasize that the plaintiff had fulfilled their obligation by tendering the required payment for freight and storage charges, further strengthening their claim to the goods. 4. Unjustified Refusal: The instruction should highlight that the defendant's refusal to deliver the goods, despite the rightful demand and tender, was without proper justification or legal excuse. 5. Intent: The instruction should instruct the jury to consider whether the defendant acted intentionally or recklessly, with knowledge that their conduct would deprive the plaintiff of the goods. It is important to note that variations of this Chicago, Illinois instruction to the jury may exist depending on the specific circumstances of the case. The specific elements and evidentiary requirements may vary, such as the nature of the goods, contractual agreements, or any additional legal defenses raised by the defendant. Therefore, it is essential for legal professionals to tailor the instruction to each individual case and the relevant legal principles associated with it.