Personal Injury Complaint Template, Free Download 2026

[NOTE TO PREPARER: Court formatting rules, including caption format, line numbering, paper size, cover sheets, and e-filing requirements, vary by jurisdiction. Review the local rules of the court where this Complaint will be filed and adapt accordingly. Delete this note before filing.] Plaintiff [____________] ("Plaintiff") is, and at all relevant times was, an individual residing in the City of [____________], County of [____________], State of [____________].

Defendant [____________] ("Defendant") is, and at all relevant times was, [an individual residing in the City of ____________, County of ____________, State of ____________ / a corporation organized under the laws of ____________ with its principal place of business at ____________]. [If applicable: Defendant [____________] was at all relevant times the owner of the vehicle operated by Defendant [____________], and/or the employer of Defendant [____________], who was acting within the course and scope of that employment, making such Defendant vicariously liable under the doctrines of respondeat superior and/or negligent entrustment.] Plaintiff is ignorant of the true names and capacities of defendants sued as DOES 1 through [____], inclusive, and will amend this Complaint to allege their true names and capacities when ascertained. [Omit Doe allegations if not permitted in the filing jurisdiction.]

This Court has subject matter jurisdiction over this action because [the amount in controversy exceeds the jurisdictional minimum of this Court / the claims arise under the common law of this State]. This Court has personal jurisdiction over Defendant because Defendant [resides in this State / committed the tortious acts alleged herein within this State / regularly conducts business within this State].

Venue is proper in this [County / District / Division] because [the collision and injuries giving rise to this action occurred within it / Defendant resides within it / a substantial part of the events giving rise to the claims occurred within it].

On or about [____________], at approximately [____] a.m./p.m., Plaintiff was [driving / a passenger in] a [year, make, model: ____________] traveling [direction: ____________] on [street / highway: ____________] at or near [cross street / landmark: ____________], in the City of [____________], County of [____________], State of [____________]. [Adapt this paragraph and those that follow for non-vehicle cases, e.g., premises liability or other negligence, by describing the place and circumstances of the incident.]

At the same time and place, Defendant was operating a [year, make, model: ____________] [describe Defendant's movement: traveling ____________ / attempting to ____________]. Defendant [describe the negligent conduct: failed to stop at a red traffic signal / followed too closely / drove at a speed unsafe for conditions / failed to yield the right of way / was distracted by ____________ / other: ____________], and thereby caused Defendant's vehicle to collide with the vehicle Plaintiff occupied (the "Collision").

As a direct and proximate result of the Collision, Plaintiff sustained injuries including [describe injuries: ____________], received medical treatment from [providers: ____________], and has incurred and will continue to incur damages as set forth below. [Reference supporting materials as appropriate: a traffic collision report, no. ____________, was prepared by ____________.]

Plaintiff realleges and incorporates by reference each and every allegation set forth above as though fully set forth herein. Defendant owed Plaintiff a duty to exercise reasonable care in the operation of Defendant's vehicle, including the duty to keep a proper lookout, to maintain control of the vehicle, to obey traffic laws and signals, and to operate the vehicle at a safe speed for the conditions then existing.

Defendant breached that duty by, among other things: (a) [failing to stop at a posted stop sign / red signal]; (b) [failing to keep a proper lookout]; (c) [driving at an unsafe speed]; (d) [following too closely]; (e) [failing to yield the right of way]; and (f) [other breaches: ____________]. As a direct and proximate result of Defendant's breach, the Collision occurred and Plaintiff suffered the injuries and damages alleged herein. Plaintiff's injuries were foreseeable consequences of Defendant's conduct, and Defendant's negligence was a substantial factor in causing them.

[OPTIONAL COUNT, include only if Defendant violated a specific safety statute, ordinance, or regulation; otherwise delete this Count and renumber.] Plaintiff realleges and incorporates by reference each and every allegation set forth above. At the time of the Collision, there was in force [identify the statute, ordinance, or regulation violated, e.g., the state vehicle code section governing ____________: cite: ____________], which was enacted to protect the class of persons of which Plaintiff is a member against the type of harm Plaintiff suffered.

Defendant violated the foregoing [statute / ordinance / regulation] by [describe the violation: ____________]. Defendant's violation was a direct and proximate cause of the Collision and of Plaintiff's injuries and damages. Under the law of this State, Defendant's violation constitutes [negligence per se / evidence of negligence], establishing or supporting the elements of duty and breach.

As a direct and proximate result of Defendant's conduct, Plaintiff has suffered and will continue to suffer economic damages, including: (a) past medical expenses of [$__________]; (b) future medical expenses in an amount to be proven at trial; (c) lost earnings of [$__________]; (d) loss of future earning capacity in an amount to be proven at trial; (e) property damage of [$__________]; and (f) other out-of-pocket expenses of [$__________].

As a further direct and proximate result of Defendant's conduct, Plaintiff has suffered and will continue to suffer non-economic damages, including physical pain, suffering, emotional distress, inconvenience, loss of enjoyment of life, [disfigurement / permanent impairment], all in an amount to be proven at trial. [If supported by the facts and permitted by law: Defendant's conduct was willful, wanton, or in conscious disregard of the rights and safety of others, entitling Plaintiff to exemplary or punitive damages in an amount to be determined at trial.]

WHEREFORE, Plaintiff prays for judgment against Defendant, and each of them, as follows: (a) economic damages according to proof at trial, but not less than [$__________]; (b) non-economic damages according to proof at trial; (c) [exemplary or punitive damages, if warranted]; (d) pre-judgment and post-judgment interest at the maximum rate permitted by law; (e) costs of suit incurred herein; and (f) such other and further relief as the Court deems just and proper.

DEMAND FOR JURY TRIAL: Plaintiff hereby demands a trial by jury on all claims and issues so triable. [Confirm the jury demand deadline and any jury fee requirements under the rules of the filing jurisdiction; some courts require a separate jury demand or deposit.]