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Bates v. State Farm Mutual Automobile Insurance Co.

United States District Court, Western District of Washington, Seattle

May 18, 2015

KASANDRA BATES, et al., Plaintiffs,
v.
STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Defendant.

ORDER DENYING MOTION AND STIPULATION TO BIFURCATE

JAMES L. ROBART, United States District Judge

Before the court are Defendant State Farm Mutual Automobile Insurance Company’s (“State Farm”) motion to bifurcate (Mot. (Dkt. # 11)) and the parties’ stipulated motion to bifurcate (Stip. (Dkt. # 13)). The parties seek to bifurcate Plaintiffs Kasandra and Justin Bates’ (“the Bates”) contractual and extra-contractual claims and stay discovery on the Bates’ extra-contractual claims pending resolution of the Bates’ contractual claims. (See Stip.) State Farm argues that bifurcation will promote judicial economy, be more convenient for the parties, and avoid jury confusion and prejudice to State Farm. (See Mot.) The court has considered State Farm’s motion, the parties’ stipulation, the balance of the record, and the relevant law. Being fully advised, the court denies the motion and the stipulation.

The decision to bifurcate is committed to the sound discretion of the trial court. Hangarter v. Provident Life & Accident Ins. Co., 373 F.3d 998, 1021 (9th Cir. 2004). The trial court’s authority to bifurcate comes from Federal Rule of Civil Procedure 42(b), which states that “[f]or convenience, to avoid prejudice, or to expedite and economize, the court may order a separate trial of one or more separate issues, claims, cross-claims, counterclaims, or third-party claims.” Fed.R.Civ.P. 42(b). Where an overlap of factual issues exists between the claims, courts are reluctant to bifurcate the proceedings. McLaughlin v. State Farm Mut. Auto. Ins. Co., 30 F.3d 861, 871 (7th Cir. 1994). Indeed, if the preliminary and separate trial of an issue would involve extensive proof and substantially the same facts or witnesses as the other issues in the cases, or if any economy in time and expense is wholly speculative, the motion should be denied. See Datel Holdings LTD. v. Microsoft Corp., No. C-09-05535 EDL, 2010 WL 3910344, at *2-5 (N.D. Cal. Oct. 4, 2010).

Numerous courts have recognized substantial overlap between the issues of coverage and bad faith, such that bifurcation of the issues would be inappropriate. Bloxham v. Mountain W. Farm Bureau Mut. Ins. Co., 43 F.Supp.2d 1121, 1129 (D. Mont. 1999); see also Tharpe v. Ill. Nat’l Ins. Co., 199 F.R.D. 213, 214 (W.D. Ky. 2001); Light v. Allstate Ins. Co., 182 F.R.D. 210, 213 (S.D. W.Va. 1998). In addition, this court regularly hears insurance cases that involve both breach of contract claims and extra- contractual claims regarding the insurer’s failure to follow insurance regulations or act in good faith. See Dees v. Allstate Ins. Co., No. C12-0483JLR, 2012 WL 3877708 (W.D. Wash. Sept. 6, 2012) (denying motion to bifurcate in a case involving underinsured motorist claims and extra-contractual claims); see also, e.g., Tilden-Coil Constructors, Inc. v. Landmark Am. Ins. Co., 721 F.Supp.2d 1007 (W.D. Wash. 2010); Hovenkotter v. Safeco Ins. Co. of Ill., No. C09-0218JLR, 2010 WL 3984828 (W.D. Wash. Oct. 11, 2010); JACO Envtl., Inc. v. Am. Int’l Specialty Lines Ins. Co., No. C09-0145JLR, 2010 WL 415067 (W.D. Wash. Jan. 26, 2010). Nothing in the complaint, the motion to bifurcate, or the parties’ stipulation compels the court to treat this case any differently. Accordingly, the court DENIES State Farm’s motion to bifurcate (Dkt. # 11) and the parties’ stipulated motion to bifurcate (Dkt. # 13).


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