401.18a Issues on Plaintiffs Claim - General Negligence - Negligence, Generally The [next] issues you must decide on (claimant)'s claim against (defendant) are whether (defendant) was negligent in (describe alleged negligence), and, if so, whether that negligence was a legal cause of the [loss] [injury] [or] [damage] to (claimant, decedent, or person for whose injury claim is made).