Many years ago, I was the appellate guy on a team of lawyers representing a Fortune 100 company in a high-stakes trial in San Antonio. The client had New York counsel, who sent down their suggested jury instructions. I was still wet behind the ears and never had seen anything like them: pages and pages of prolix instructions in confusing legalese. Needless to say, none of them made it into the jury charge.
For a time, I thought it was simply that New York lawyers were insane. But now, after assisting with trials outside Texas, I know that those instructions typified what courts elsewhere provide. The jury instructions in other states tend to be verbose, confusing and often couched in opaque legal jargon.
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