Cuyahoga Ohio Instruction to Jury that Refusal to Deliver Goods after Demand and Tender of Freight and Storage Charges can Constitute Conversion is a legal concept that pertains to the unlawful act of withholding goods after a rightful demand for delivery has been made, accompanied by an offer to pay the relevant freight and storage charges. This instruction is crucial in cases where the refusal to deliver goods can be deemed as conversion, a civil action that allows the injured party to seek compensation for the loss or damage caused by the wrongful act. In Cuyahoga Ohio, several types of instructions to the jury can be provided for cases involving Refusal to Deliver Goods after Demand and Tender of Freight and Storage Charges, including: 1. Standard Instruction: This type of instruction educates the jury about the general principles of conversion, emphasizing that the refusal to deliver goods after a proper demand and tender of payment can amount to an act of conversion. It outlines the essential elements that need to be satisfied before a claim of conversion can be successful. 2. Instruction on Reasonable Time: In cases where the party refusing to deliver goods raises a defense of insufficient time to comply with the demand, an instruction on reasonable time can be given to the jury. This instruction clarifies that a reasonable time should be determined based on the circumstances of each case, taking into account factors such as the nature of the goods, their location, and any applicable transportation constraints. 3. Instruction on Proper Demand: When disputes arise regarding the sufficiency of the demand made for goods' delivery, an instruction on proper demand is provided to guide the jury. This instruction emphasizes the elements necessary for a proper demand, such as specificity regarding the goods, the location to which they should be delivered, and the inclusion of a reasonable timeframe for compliance. 4. Instruction on Tender of Freight and Storage Charges: This specific instruction highlights the importance of tendering the appropriate freight and storage charges along with the demand for goods' delivery. It explains that the refusal to deliver goods after a valid demand, accompanied by a proper offer to pay the required charges, can be deemed as conversion. Overall, these various types of instructions help the jury understand the legal requirements and nuances associated with Refusal to Deliver Goods after Demand and Tender of Freight and Storage Charges in Cuyahoga Ohio. By clarifying the elements required for conversion and providing guidance on specific issues that may arise during the litigation process, these instructions enable the jury to make informed decisions based on the evidence presented before them.