Rule 3.1580.Request for special findings by jury

A jury’s general verdict tells the parties who won, but it does not always say why. Special findings fill that gap by asking the jury to answer discrete factual questions along with its verdict. Rule 3.1580 sets the mechanics for requesting them: the request has to be written, not raised orally during argument or after the jury has already retired to deliberate.

Timing matters. A party who wants special findings has to present the proposed issues or questions to the judge before argument begins, unless the court has ordered a different schedule. Waiting until closing argument, or until deliberations are underway, comes too late absent a court order permitting it.

The rule also requires the questions to arrive ready to use, drafted in a form the court could hand straight to the jury, and it requires service on every other party. That advance notice lets opposing counsel object to the phrasing or scope of a proposed question before the jury ever sees it, rather than raising the issue for the first time after trial.