Motion to Bifurcate; Motion to prohibit reference to Defendant’s financial condition
23CV013523: JAPLIT vs AMERICAN HONDA MOTOR COMPANY, INC., et al. 03/13/2026 Hearing on Motion to Bifurcate in Department 47
Tentative Ruling
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The motion of Defendant American Honda Motor Co., Inc. (Defendants) to bifurcate trial and to prohibit reference to Defendants financial condition during the first phase of trial is ruled on as follows.
Civil Code § 3295(d) requires the Court, on application of any defendant, to preclude the admission of evidence of the moving defendant's profits or financial condition until after a verdict has been returned awarding a plaintiff actual damages and finding the defendant is guilty of malic, oppression or fraud. 'The purpose behind Civil Code section 3295, which allows bifurcation and preclusion of evidence of a defendant's wealth and profits during the liability phase of trial, is to minimize prejudice prior to the jury's determination of a prima facie case of liability for punitive damages.' (Notrica v. State Comp. Ins. Fund (1999) 70 Cal.App.4th 911, 939.) Such evidence is not excluded when relevant to liability. (Ibid.)
The motion to bifurcate the issue of punitive damages is GRANTED. However, the Court makes no determination at this time as to what evidence is admissible in each phase of trial. A request to exclude evidence under Civil Code § 3295
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23CV013523: JAPLIT vs AMERICAN HONDA MOTOR COMPANY, INC., et al. 03/13/2026 Hearing on Motion to Bifurcate in Department 47
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