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Fourth Department – Bifurcation: Calvaneso v. Mochol
Daily Record Staff//June 15, 2026//
New York State Supreme Court, Appellate Division, Fourth Judicial Department
Bifurcation — Motor-vehicle accident — Nature of injuries
CA 25-00651
Appealed from Supreme Court, Erie County
Background: The plaintiff commenced an action seeking damages for injuries resulting from a motor vehicle accident. The defendants appealed from the denial of their motion to bifurcate the liability and damages portions of the trial.
Ruling: The Appellate Division affirmed. The court held the plaintiff established that the nature of her injuries as an important bearing on the issues of liability and bifurcation would not assist in clarification or simplification of the issues and a fair and more expeditious resolution of the action.
Tyler J. Eckert, of Hurwitz Fine, for the defendants-appellants; Leah Costanzo, of Steve Boyd, for the plaintiff-respondent.
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