I.R. v. Santos

Summary

The Appellate Division, Second Department, reversed an order denying the plaintiffs' motion for a unified trial on liability and damages in a personal-injury action. The court held that conflicting accounts of the accident and evidence concerning the infant plaintiff's injuries made the nature of the injuries probative of how the accident occurred. The court therefore granted the motion for a unified trial.

Holdings

1. A unified trial should be granted where the nature of the plaintiff's injuries has an important bearing on liability; because the parties offered conflicting accounts of the accident and the injury evidence was probative of how the accident occurred, the trial court improvidently exercised its discretion in denying the motion.
2. The decision whether to conduct a bifurcated or unified trial is committed to the trial court's discretion and should not be disturbed absent an improvident exercise of that discretion.

Questions Presented

1. Whether the trial court improvidently exercised its discretion by denying the plaintiffs' motion for a unified trial on liability and damages.
2. Whether the nature of the infant plaintiff's injuries had an important bearing on the disputed issue of liability and therefore supported a unified trial.

Disposition

reversed