How to cite pattern jury instructions (including CACI)
You want to cite a pattern or model jury instruction: CACI in a California case, or a federal circuit's model set. What is the form? Do you need an edition or a revision date? And what does citing a pattern instruction actually prove?
If you use a set we haven't covered (CALCRIM, another state's set, another circuit's), reply below with how its publisher asks to be cited.
The team’s answer
Short answer. Use the instruction's number in the form the issuing body asks for, and say which edition you used when the wording has changed over time. For CACI, the official 2026 edition prints the form: "CACI No." and the number. For a federal model set that gives no citation line, name the set, the instruction number and the edition.
CACI [Jurisdiction-specific]
The 2026 edition's front matter says to cite the instructions as "CACI No." followed by the instruction number, and the verdict forms as "CACI No. VF-" followed by the number. To cite the publication as a whole, it gives: Judicial Council of California Civil Jury Instructions (2026 edition).
CACI No. 400 is Negligence—Essential Factual Elements. CACI No. VF-400 is the matching verdict form, Negligence—Single Defendant.
Each instruction prints its history. CACI No. 400's reads: New September 2003; Revised February 2005, June 2005, December 2007, December 2011.
[House style] When your argument turns on the wording in force at a particular time, such as the date of trial, say which edition or revision you mean.
What the rule of court says [Jurisdiction-specific]
The Judicial Council's instructions are California's official instructions, their use is strongly encouraged, and they are kept up to date through the Council's advisory committees. Cal. Rules of Court, rule 2.1050(a), (e), (f).
The same rule leaves stating and interpreting California law to the Legislature and the reviewing courts. Rule 2.1050(b).
[House style] So cite a statute or a case for the law itself, and CACI for the instruction.
Federal model sets [House style]
The Ninth Circuit's civil set is the Manual of Model Civil Jury Instructions, prepared by the circuit's Jury Instructions Committee: 2025 edition, last updated August 2026. The circuit's jury-instructions page says the 2025 print edition is current only through October 2025, while the online instructions are current through August 2026, and it posts a table converting old instruction numbers to new ones. The manual itself says its instructions are models, not mandatory, and that the court of appeals does not adopt them as definitive.
The manual gives no citation line, so we would write:
Ninth Circuit Manual of Model Civil Jury Instructions, Instruction 1.6 (2025 ed., last updated Aug. 2026).
That is instruction 1.6, Burden of Proof—Preponderance of the Evidence.
For any other set, look for a citation line in the front matter before you choose a form.
Common mistakes
Dropping "VF-" from a CACI verdict form, which sends the reader to the instruction with the same number.
Citing an old instruction number after a set has been renumbered. Check the Ninth Circuit's conversion table.
Quoting the online text of an instruction while citing the print edition, when the two differ.
Citing CACI alone for a rule of law. Rule 2.1050(b) leaves stating the law to the Legislature and the reviewing courts, so cite them too.
Read more
The Court Documents chapter, which covers jury instructions (its opening is free to read): https://citationcode.com/book/court-documents (opens in a new tab)
The official texts we read:
CACI, 2026 edition: https://courts.ca.gov/system/files/file/judicial_council_of_california_civil_jury_instructions_2026.pdf (opens in a new tab)
Cal. Rules of Court, rule 2.1050: https://courts.ca.gov/cms/rules/index/two/rule2_1050 (opens in a new tab)
Ninth Circuit Manual of Model Civil Jury Instructions: https://www3.ce9.uscourts.gov/jury-instructions/model-civil (opens in a new tab)