Arizona Civil Jury Instructions: RAJI Authority, Use, and Objections

The Arizona civil jury instructions, known as the Revised Arizona Jury Instructions (Civil) or RAJI (Civil), are the model instructions the State Bar of Arizona publishes for use in civil trials. They translate statutes and case law into language jurors can follow, and Arizona Rule of Civil Procedure 51 governs how attorneys propose them, how judges rule on them, and how parties preserve objections for appeal. Judges use them routinely, but they are persuasive rather than binding.

Who Writes RAJI and What Weight It Carries

The Civil Jury Instructions Committee of the State Bar of Arizona drafts and maintains RAJI (Civil), with the State Bar’s Board of Governors overseeing publication. The committee’s job is to keep the instructions in line with current Arizona statutes and appellate decisions.

The original publications were titled “Recommended Arizona Jury Instructions” because the Arizona Supreme Court reviewed and approved them before publication. The Supreme Court later stopped issuing advance approval for jury instructions outside the context of appellate cases. The Board of Governors then renamed the publications “Revised Arizona Jury Instructions” and added a disclaimer noting that the instructions have not been approved by the Supreme Court.¹

The practical consequence is that RAJI is persuasive, not mandatory. Courts and attorneys are expected to satisfy themselves in each case, using original and current authority, that the instructions being given are appropriate and correct. The most current version is the RAJI (Civil) 8th Edition, published in October 2025. Earlier editions, including the 7th Edition published in 2020, remain available through the State Bar website and through commercial publishers like LexisNexis.²

How RAJI Is Organized

RAJI (Civil) is divided into topical sections that track the phases of a civil trial and the major areas of civil law. The first two sections handle the procedural framework. Preliminary Instructions are given right after the jury is sworn. Standard Instructions cover foundational concepts like evaluating evidence, burden of proof, and witness credibility.³

The remaining sections cover specific civil claims. In a typical personal injury case, the case-specific instructions come from the Fault, Negligence, Medical Negligence, or Product Liability sections, while damages instructions come from the Personal Injury Damages section.⁴ Other specialized sections cover Contract Instructions, Intentional Torts, and Employment Law, among others.

What Jurors Hear First

Arizona Rule 51(b)(2) requires the court to instruct the jury on several topics immediately after it is sworn, before any evidence is heard.⁵ The required subjects are:

Juror duties and conduct, including deciding facts on the evidence and avoiding speculation or sympathy
The order of proceedings
The procedure for jurors to submit written questions to witnesses or the court
Whether and how jurors may take notes
What counts as evidence, the difference between direct and circumstantial evidence, and how to evaluate it
A preview of the issues, claims, and defenses
The substantive legal principles the jury will apply
What jurors should do if problems arise during trial

The RAJI Preliminary Instructions supply model language for these requirements, along with instructions on expert testimony, the distinction between attorney statements and actual evidence, an admonition against outside research including internet searches, and guidance on media coverage.² The committee’s guidance is that preliminary instructions should cover enough substantive ground to orient the jury without creating conflicts with the final instructions.

How Attorneys Propose Instructions

Rule 51(a) controls the request process. A party may file written requests for instructions before trial or, with the court’s permission, during trial. After the evidence closes, a party can still request instructions on issues that could not reasonably have been anticipated by the pretrial deadline, or can seek leave to file late requests on any issue.⁵

In practice, the court’s scheduling order sets the specific deadline for submitting proposed instructions. Many judges require the parties to confer and file a joint set of agreed instructions, with separate submissions reserved for disputed instructions. Rule 51 does not require each proposed instruction to carry a RAJI number or citation, but that is standard practice, and most judges expect it. Identifying each instruction by its RAJI designation helps the court quickly assess whether the proposed instruction accurately states the law.

Before instructing the jury and before closing arguments, the court must inform all parties of the instructions it intends to give and its rulings on any disputed requests.⁵ That advance notice lets attorneys shape closing arguments to the instructions the jury will actually hear and lodge objections before the final charge is read.

The Charge Conference

The judge typically holds a conference with counsel, outside the jury’s presence, to work through each proposed instruction. The court may give an instruction as proposed, refuse it, or modify it, and must indicate any modifications on the record. The court must also make a record of its rulings on all requests.⁵ Most instruction disputes play out here. A prepared attorney brings alternative language to the conference in case the court rejects the first version.

When No RAJI Fits the Issue

RAJI does not address every legal theory or factual scenario in civil litigation. When no standard instruction covers a point, attorneys draft custom instructions. The guiding principle is that non-RAJI instructions should be added only to the extent needed, and they must be verified against original, current legal authority to ensure accuracy.¹ Custom instructions that drift from settled law or add argumentative language are the ones most likely to draw objections and create appellate issues.

Written Copies and Plain Language

Rule 51(b)(1) requires each juror to receive a written copy of both the preliminary and final instructions before the instructions are read aloud and before the jury retires to deliberate.⁵ The rule also directs that jury instructions be “as readily understandable as possible by individuals unfamiliar with the legal system.” That language is operative, not aspirational. Instructions overloaded with jargon or tangled syntax can draw valid objections on readability grounds alone.

Objecting and Preserving Error for Appeal

A bad instruction on the record is worth nothing if the objection is not made correctly. Rule 51(c) requires that any objection to an instruction, or to the court’s failure to give one, be made on the record. The objection must distinctly state what is being challenged and the specific legal grounds for the challenge.⁵ A vague objection along the lines of “we object to instruction number twelve” preserves nothing.

The objection is timely if made at the opportunity the court provides under Rule 51(b)(3)(C), which is the window the court must give parties to object on the record, outside the jury’s hearing, before the instructions and arguments are delivered. If a party was not informed of an instruction or ruling before that opportunity, the party can object promptly after learning of it.⁵

Under Rule 51(d)(1), a party can assign error on appeal in two situations. The first is when an instruction that was actually given contained an error and the party properly objected. The second is when the court failed to give a requested instruction and the party both properly requested it and properly objected to the refusal. If the court made a definitive ruling on the record rejecting the request, that ruling satisfies the objection requirement.⁵

Fundamental Error

Failing to object does not always kill the issue on appeal. Rule 51(d)(2) allows a court to consider a “fundamental error as allowed by law, even if the error was not preserved.”⁵ This is a narrow exception. Arizona appellate courts invoke it sparingly, reserving it for instructional errors that go to the foundation of the case and deprive a party of a fair trial. Treating fundamental error as a backup plan is a losing bet. A clear, specific, on-the-record objection at trial is the safer course.

Practical Points

Start drafting early. The scheduling order sets your deadline, and drafting instructions forces you to identify the elements you need to prove, which sharpens trial preparation.
Use RAJI as the default. Judges are more comfortable giving instructions they recognize. When a standard RAJI instruction covers the issue, start there and modify only if necessary.
Cite your authority. Rule 51 does not expressly require citations on each proposed instruction, but judges expect them. An instruction without a statute or case citation invites skepticism.
Object with precision. State which instruction you challenge, identify the specific legal error, and explain what the instruction should say instead.
Get a definitive ruling. If the court rejects your requested instruction on the record in a definitive ruling, you have preserved the issue. If the ruling is ambiguous, object anyway.

Because each juror carries a written copy of the instructions into deliberations, the drafting matters as much as the delivery. Clear language gives the jury something to work from; convoluted language does not.

1
State Bar of Arizona. Revised Arizona Jury Instructions (Criminal) 6th Edition
2
State Bar of Arizona. Revised Arizona Jury Instructions Civil – Preliminary Instructions
3
State Bar of Arizona. Revised Arizona Jury Instructions (Civil) 8th – Standard Instructions
4
State Bar of Arizona. Revised Arizona Jury Instructions Civil – Personal Injury Damages
5
New York Codes, Rules and Regulations. Arizona Rules of Civil Procedure, Rule 51 – Jury Instructions; Objections; Preserving a Claim of Error