UJI 13-413 NMRA
UJI 13-413. Liability of employer or co-employee defendant.
____________________ (defendant employer or co-employee), is responsible only
for damages caused to _________________ (plaintiff) only if _____________________
(employer or co-employee) intentionally or willfully injured ____________________
(plaintiff).
__________________ (employer or co-employee) acted intentionally in [committing
an act] [or] [failing to act] if the [employer] [co-employee] knew or should have known,
under the conditions existing at the time, that _________________ (plaintiff) was
substantially certain to be injured as a result.
__________________ (employer or co-employee) acted willfully if the [employer]
[co-employee]:
1. intentionally [acted] [or] [failed to act], without just cause or excuse in a way
reasonably expected to result in injury to _________________ (plaintiff); and
2. either expected the injury to occur or utterly disregarded the consequences of the
[act] [or] [failure to act].