Separating phases of a trial, known as bifurcation, often occurs when failing to do so would introduce issues in another phase that would improperly influence the jury. For example, in a criminal DUI case, if a defendant had a prior DUI, the case might be split into the guilt and sentencing phases so that the jury would not be influenced by the prior DUI in deciding whether the defendant is guilty. In a Maryland civil DUI case, the case might be split into a compensatory damages phase and a punitive damages phase, so that the jury would not be influenced by the fact that the defendant was driving drunk in deciding the amount of damages the plaintiff should be awarded. Similar concepts apply in Maryland car accident cases.
In Maryland, the trial judge has the discretion to decide whether to bifurcate or trifurcate a trial. The trial judge’s decision may be overturned if the trial judge abused his or her discretion. Under Maryland Rule of Civil Procedure Rule 2-503, a judge may separate trial of a claim or issue because it would be convenient or to avoid prejudice.
In a recent case, the judge decided to bifurcate compensatory and punitive damages phases of a DUI accident trial but allowed evidence of the defendant’s intoxication in the compensatory damages phase. In that case, the plaintiff was stopped at a red light and was rear-ended by the defendant driver. The plaintiff filed negligence claims against the defendant driver and against the entity that owned the vehicle. The defendant driver was drunk at the time of the crash, and the plaintiff sought both compensatory and punitive damages. The jury found in favor of the plaintiff and awarded over $2.5 million in compensatory damages and subsequently awarded $15,000 in punitive damages.
However, the defendants appealed, arguing that the court should not have allowed evidence concerning the defendant driver’s intoxication in the compensatory damages phase. The appeals court found the bifurcation was proper in this case because both compensatory and punitive damages were at issue. Yet, the appeals court decided that the trial court should not have allowed evidence to be introduced during the compensatory damages phase on the defendant’s intoxication. Despite telling the jury it could not consider such evidence, the plaintiff repeatedly referenced the fact that the defendant was intoxicated at the time of the accident. The appeals court decided the evidence was not relevant and substantially prejudicial, and that it was an abuse of discretion for the court to allow such evidence. Thus, the court sent back the case for a new trial.
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If you are dealing with the aftermath of a crash, you cannot afford to take any chances. The skilled Maryland car accident lawyers at Lebowitz & Mzhen, LLC have advocated for victims for decades. We guide our clients through each step of the legal process and strive to get your life back on track. To set up a free consultation regarding an auto crash or another type of accident, call us toll-free at (800) 654-1949 or contact us online.