Tentative Rulings

The Tentative Rulings for Wednesday, April 8, 2026, are:

Re:               Matevosyan, Maria vs. CNH Industrial N.V.

Case No.:  VCU296053

Date:          April 8, 2026

Time:          8:30 A.M. 

Dept.          7-The Honorable Nathan D. Ide

Motion:    (1) Defendants’ Motion to Bifurcate; (2) Defendants’ Motion to Continue Trial

Tentative Ruling: (1) To deny the motion; (2) The Court does not issue tentative rulings on these motions; counsel may appear in any manner.

(1) Defendants’ Motion to Bifurcate

Facts

On February 22, 2023, the Plaintiffs filed their complaint alleging product liability and negligence claims against the defendants. Plaintiffs allege that Markar Matevosyan was killed while working with a Steiger 435 tractor bearing product identification number ZAF11829. Plaintiffs filed this action under claims of product liability and negligence claims.

On July 5, 2023, Defendant, CNH Industrial America LLC, filed their answer.

On July 10, 2023, Defendant, Linder Equipment Co., filed their answer.

Defendants move to bifurcate issues of liability and damages, arguing that this would avoid prejudice and provide convenience, would promote judicial economy and efficiency, would expediate trial. The motion generally sets forth the expected number of fact and expert witnesses as to each proposed phase.

In opposition, Plaintiffs argue that a bifurcated trial would require additional days, do not show a dispositive affirmative defense as to liability and that the overlap of witnesses is not minimal. Further, that Defendants fail to quantify the efficiency purposed by bifurcation.

Authority and Analysis

Whether to order bifurcation of issues for trial is typically discretionary (Code Civ. Proc. §§ 598, 1048(b); Grappo v. Coventry Financial Corp. (1991) 235 Cal.App.3d 496, 504).

The objective of bifurcation is to avoid wasting time and money on the trial of damages if the liability issue is resolved against plaintiff.  (Horton v. Jones (1972) 26 Cal.App.3d 952, 954.) Granting or denying of a motion for bifurcation lies within the trial court’s sound discretion and is subject to reversal on appeal only for clear abuse.  (Grappo v. Coventry Financial Corp. (1991) 235 Cal.App.3d 496, 503-504.) 

Under Code of Civil Procedure section 1048(b):

“The court, in furtherance of convenience or to avoid prejudice, or when separate trials will be conducive to expedition and economy, may order a separate trial of any cause of action, including a cause of action asserted in a cross-complaint, or of any separate issue or of any number of causes of action or issues, preserving the right of trial by jury required by the Constitution or a statute of this state or of the United States.”  

Similarly, Code of Civil Procedure section 598 provides: 

“The court may, when the convenience of witnesses, the ends of justice, or the economy and efficiency of handling the litigation would be promoted thereby, on motion of a party, after notice and hearing, make an order, no later than the close of pretrial conference in cases in which such pretrial conference is to be held, or, in other cases, no later than 30 days before the trial date, that the trial of any issue or any part thereof shall precede the trial of any other issue or any part thereof in the case, except for special defenses which may be tried first pursuant to Sections 597 and 597.5. The court, on its own motion, may make such an order at any time.”

Section 598 was expressly adopted as the result of Judicial Council recommendations and “Its objective is avoidance of waste of time and money caused by unnecessary trial of damage questions in cases where the liability issue is resolved against the plaintiff.”  (Trickey v. Superior Court (1967) 252 Cal.App.2d 650, 653)

Finally, Evidence Code section 320 states that: “[e]xcept as otherwise provided by law, the court in its discretion shall regulate the order of proof.” “Under these provisions, trial courts have broad discretion to determine the order of proof in the interests of judicial economy.”  (Grappo v. Coventry Financial Corp. (1991) 235 Cal.App.3d 496, 504.)

California courts have recognized that bifurcation is proper where liability is a simple matter while damages require testimony from multiple witnesses, or where only a small fraction of the evidence would be repeated, and the trial court had determined the ends of justice would be served by bifurcation.  (See Trickey, supra, at 652-653 – one witness in addition to the parties; Kaiser Steel Corp. v. Westinghouse Elec. Corp. (1976) 55 Cal.App.3d 737, 745-746 (superseded by statute on other grounds in Barnett v. American-Cal Medical Services (1984) 156 Cal.App.3d 260 – “the trial court could properly conclude that while some evidence relating to damages would also be necessary on the issue of liability, only a small fraction of the evidence would be repeated so that the ends of justice were served by bifurcation.”)

Here, Defendants have failed to provide specific information as to the two proposed phases, including the likely length of the anticipated testimony as to the fact and expert witnesses, and the amount of time saved if a defense verdict is entered on liability as compared to the additional time needed for an extra set of openings/closings and an extra round of jury deliberations if Plaintiff prevails.

The generalized arguments set forth by Defendants are concerns in every case that involves liability and damages.

Jurors will be instructed as to their own emotions, compassions and sympathies, thereby reducing any concern of bias or undue prejudice. This accident does not appear to have  facts that uniquely tend to evoke an emotional bias against a defendant without relevancy, as least within the standard set forth by Evidence Code section 352. (People v. Kipp (2001) 26 Cal.4th 1100, 1121.) The Court does not find the evidence indicated above unduly prejudicial to warrant bifurcation.

Finally, the Court will not weigh the evidence or likelihood of Defendants prevailing at trial on liability.

Therefore, the Court denies the motion.

If no one requests oral argument, under Code of Civil Procedure section 1019.5(a) and California Rules of Court, rule 3.1312(a), no further written order is necessary. The minute order adopting this tentative ruling will become the order of the court and service by the clerk will constitute notice of the order

Examiner Notes for Probate Matters Calendared

• Visalia Division 
• South County Justice Center Division