Rule 1.924.Instructions

Jury instructions translate the law into guidance a jury can use, and Rule 1.924 governs how that happens. The court must instruct the jury on the law applicable to all material issues, in writing, in consecutively numbered paragraphs, read to the jury without comment or explanation — unless the parties agree that the instructions may be given orally instead. Any party may file written requests for particular instructions at the close of the evidence, or at an earlier time the court reasonably sets.

The rule builds in a careful sequence before argument. The court must first give counsel a preliminary draft of the instructions it expects to give on controversial issues — a draft that does not become part of the record — and then, before jury arguments, must give each side a copy of the instructions in their final form, noting that on the record and allowing reasonable time for objections. Those objections must be made and ruled on before arguments to the jury begin, and within that window, all objections to giving or refusing an instruction must be made in writing or dictated into the record, outside the jury's presence, specifying both the matter objected to and the grounds.

The consequence for missing that window is real: no other grounds or objections may be raised later, or considered on appeal. If the court later revises or adds to the instructions, a similarly specific objection can still be made in the motion for new trial, but skipping that step waives it too. The rule also allows the court to read one or more final instructions to the jury at any stage of trial, as long as counsel had a chance to review them and object, and any instructions read early must be included again in the instructions read after the evidence closes.