401.19 Issues on Plaintiff's Claim - Common Carrier The [next] issues on (claimant)'s claim for you to decide are: whether (defendant) in (describe conduct) failed to exercise the highest degree of care for the safety of (claimant); and, if so, whether that failure was a legal cause of the [loss] [injury] [or] [damage] to (claimant, decedent, or person for whose injury claim is made).