Rule 51: Instructions to the Jury; Objections

Jury instructions tell the jury what the law is and how to apply it to the facts. Rule 51 governs the process by which parties request specific instructions and preserve their objections for appeal.

Before the jury is instructed, the court informs the parties of the instructions it plans to give. Parties then have an opportunity to object on the record, and they must state the specific grounds for any objection. This is critical for appellate review: if you fail to object to an instruction (or the omission of a requested instruction), you generally waive the right to challenge it on appeal. The only exception is plain error — an error so fundamental that it affects substantial rights and must be corrected to prevent a miscarriage of justice.

Parties may also submit their own proposed instructions, which the court can adopt, modify, or reject. A well-crafted jury instruction request is a key piece of trial advocacy — it frames the legal standard in the way most favorable to your client while remaining accurate.