IN THE DISTRICT COURT OF THE [___] JUDICIAL DISTRICT

IN AND FOR [__] COUNTY, STATE OF UTAH

[PLAINTIFF NAME], an individual,
  Plaintiff,

v.

[DEFENDANT NAME], a [corporation/LLC/individual/etc.],
  Defendant.

COMPLAINT
(Personal Injury – Negligence)
JURY DEMAND ENDORSED HEREON

Civil No.: [__]
Judge: [Hon. ___]
Tier Designation under URCP 26: [Tier 2 / Tier 3]

[// GUIDANCE: Select Tier 2 if the total damages claimed are ≤ $300,000; Tier 3 if > $300,000.]

TABLE OF CONTENTS

1. Document Header
2. Definitions
3. Jurisdiction & Venue
4. Parties
5. General Allegations of Fact
6. Cause of Action – Negligence
7. Damages Allegation
8. Reservation of Rights
9. Prayer for Relief
10. Jury Demand
11. Verification (Optional)
12. Signature Block

1. DOCUMENT HEADER

1.1 Effective Filing Date: [DATE OF FILING]
1.2 Governing Law: Utah tort law, including Utah Code Ann. §§ 78B-5-817 et seq. (Comparative & Joint Liability) and any applicable statutory damage caps.
1.3 Forum: State court pursuant to metadata directive (no arbitration).

2. DEFINITIONS

For ease of reference, the following capitalized terms shall have the meanings set forth below and shall apply throughout this Complaint:

“Accident” – The incident that occurred on [DATE] at/near [LOCATION] resulting in Plaintiff’s injuries.
“Caps” – Any statutory limitation on damages, including but not limited to Utah Code Ann. § 63G-7-604 (Governmental Immunity) or § 78B-3-410 (Health-Care Malpractice), as may be applicable.
“Complaint” – This pleading, together with all exhibits, addenda, and any amendments or supplements hereto.
“Defendant” – [DEFENDANT NAME] and any predecessors, successors, parents, subsidiaries, affiliates, employees, or agents whose conduct is at issue.
“Joint Liability Rules” – Utah’s comparative fault and several liability statutes codified at Utah Code Ann. §§ 78B-5-817 to -823.
“Negligence Standard” – The common-law duty to exercise reasonable care under the circumstances as recognized in Utah.
“Plaintiff” – [PLAINTIFF NAME], including lawful heirs, assigns, representatives, and insurers with subrogation rights.

3. JURISDICTION & VENUE

3.1 This Court has subject-matter jurisdiction pursuant to Utah Code Ann. § 78A-5-102 because the amount in controversy exceeds the statutory minimum for district courts and sounds in tort.
3.2 Personal jurisdiction is proper because Defendant [is domiciled in / regularly conducts business in / committed the tortious act within] the State of Utah.
3.3 Venue lies in [__] County under Utah Code Ann. § 78B-3-307(1) because the Accident occurred in this county and/or Defendant resides or does business herein.

4. PARTIES

4.1 Plaintiff is an individual residing at [FULL RESIDENTIAL ADDRESS], County of [__], State of Utah.

4.2 Defendant is a [corporation/LLC/individual] organized under the laws of [STATE] with its principal place of business at [ADDRESS] and may be served through its registered agent:
  Name: [_]
  Address: [_]

[// GUIDANCE: If multiple defendants, replicate § 4 with appropriate designations (e.g., “Defendant #2”).]

5. GENERAL ALLEGATIONS OF FACT

5.1 On [DATE], at approximately [TIME], Plaintiff was lawfully present at/near [LOCATION] when the Accident occurred.

5.2 Defendant owed Plaintiff the Negligence Standard duty to exercise reasonable care, including but not limited to [specific statutory/regulatory duties, if any, e.g., traffic regulations under Utah Code Ann. § 41-6a-601].

5.3 Defendant breached that duty by, inter alia:
  a. [Driving at an excessive speed];
  b. [Failing to maintain a proper lookout];
  c. [Operating a vehicle while distracted/intoxicated]; and/or
  d. [Other acts or omissions].

5.4 As a direct and proximate result of Defendant’s breach, Plaintiff suffered severe bodily injuries including but not limited to [LIST INJURIES], necessitating medical treatment and causing permanent impairment.

5.5 Plaintiff incurred reasonable and necessary medical expenses of approximately $[__] to date and anticipates future medical expenses of approximately $[____].

5.6 Plaintiff has sustained lost wages and loss of earning capacity estimated at $[______].

5.7 Plaintiff has endured physical pain, mental anguish, loss of enjoyment of life, and other non-economic damages.

5.8 No comparative fault is attributable to Plaintiff; alternatively, any comparative fault of Plaintiff is less than 50% such that recovery is not barred under Utah Code Ann. § 78B-5-818(2).

6. CAUSE OF ACTION – NEGLIGENCE

6.1 Plaintiff realleges and incorporates paragraphs 1 through 5.8 as if fully set forth herein.

6.2 Duty. Defendant owed Plaintiff the Negligence Standard duty of ordinary care under the circumstances.

6.3 Breach. Defendant breached said duty as detailed in § 5.3.

6.4 Causation. Defendant’s breach was the actual and proximate cause of Plaintiff’s injuries and damages.

6.5 Damages. Plaintiff suffered damages described in § 7, subject to the Caps where applicable.

WHEREFORE, Plaintiff seeks the relief set forth in the Prayer for Relief, infra.

7. DAMAGES ALLEGATION

7.1 Economic Damages
  a. Past medical expenses: $[__]
  b. Future medical expenses: $[_]
  c. Past lost wages: $[]
  d. Future loss of earning capacity: $[___]

7.2 Non-Economic Damages (subject to applicable Caps, if any)
  a. Pain and suffering;
  b. Emotional distress;
  c. Loss of enjoyment of life;
  d. Permanent impairment/disfigurement.

7.3 Punitive Damages
  Plaintiff reserves the right to seek punitive damages under Utah Code Ann. § 78B-8-201 upon a proper showing of Defendant’s willful or reckless conduct.

7.4 Interest & Costs
  Plaintiff seeks pre- and post-judgment interest as allowed by law, together with allowable costs under URCP 54(d).

[// GUIDANCE: If the defendant is a health-care provider, ensure compliance with Utah’s medical malpractice pre-litigation panel requirements (§ 78B-3-412) and adjust Caps accordingly (§ 78B-3-410).]

8. RESERVATION OF RIGHTS

8.1 Plaintiff expressly reserves the right to amend this Complaint to add additional parties, claims, theories of liability, or damages as discovery progresses, consistent with URCP 15.

9. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully prays for judgment against Defendant as follows:

a. Economic damages in an amount to be proven at trial;
b. Non-economic damages, subject to statutory Caps, in an amount to be determined by the trier of fact;
c. Punitive damages as permitted by law;
d. Pre- and post-judgment interest as allowed by Utah law;
e. Costs of suit and such other relief as the Court deems just and proper.

10. JURY DEMAND

Pursuant to Article I, § 10 of the Utah Constitution and URCP 38, Plaintiff demands a trial by jury on all issues so triable.

11. VERIFICATION (OPTIONAL)

STATE OF UTAH )
: ss )
COUNTY OF [____])

I, [PLAINTIFF NAME], being first duly sworn, state that I am the Plaintiff in the above-entitled matter; I have read the foregoing Complaint and know the contents thereof; the same is true to the best of my knowledge, information, and belief.

[PLAINTIFF NAME]

Subscribed and sworn before me on this ___ day of ____, 20__, by [PLAINTIFF NAME].

Notary Public
My Commission Expires: _______

[// GUIDANCE: Verification is generally optional in Utah civil cases but may be required if a statute imposes it (e.g., certain governmental claims). Remove if not desired.]

12. SIGNATURE BLOCK

Respectfully submitted this ___ day of _____, 20__.

[ATTORNEY NAME] (Utah Bar No. ______)
[LAW FIRM NAME]
[ADDRESS]
[PHONE] | [EMAIL]
Attorney for Plaintiff

CERTIFICATE OF SERVICE

I hereby certify that on the ___ day of _____, 20__, I caused a true and correct copy of the foregoing Complaint to be [e-filed and] served upon the following via [method], pursuant to URCP 5:

[DEFENSE COUNSEL NAME]
[FIRM]
[ADDRESS]
[EMAIL]

[ATTORNEY NAME]

[// GUIDANCE:
1. Insert specific factual allegations and adjust legal theories as needed (e.g., premises liability, strict products liability).
2. If suing multiple defendants, apportion fault per § 78B-5-818 and plead alternative theories.
3. Consider early Rule 68 offer-of-judgment strategy to shift costs if appropriate.
4. Review local court standing orders for additional pleading or scheduling requirements.
]