“Plaintiff claims that he was harmed by Defendant while Plaintiff was performing his job duties as [specify, e.g., a firefighter]. Defendant is not liable if Plaintiff’s injury arose from a risk inherent in the occupation of [e.g., firefighter]. However, Plaintiff may recover if he proves all of the following: 1. That Defendant unreasonably increased the risks to Plaintiff over and above those inherent in [e.g., firefighting], that Defendant [misrepresented to/failed to warn] Plaintiff [of] a dangerous condition that Plaintiff could not have known about as part of his job duties, or that the cause of Plaintiff’s injury was not related to the
inherent risk; 2. That Plaintiff was harmed; and 3. That Defendant ’s conduct was a substantial factor in causing Plaintiff’s harm.”
[CACI Jury Instructions [citations omitted]]
