Castro v. Malia Realty, LLC
Manuel Castro, a construction worker, and his wife sued Malia Realty, LLC, the construction site owner, for personal injuries after Castro allegedly fell from a scaffold. Malia Realty, LLC, then commenced a third-party action against Target Contracting, LLC, Castro's employer. Plaintiffs alleged common-law negligence and violations of Labor Law §§ 200, 240(1), and 241(6). The Supreme Court denied the plaintiffs' motion for a unified trial, citing a perceived strict Second Department rule favoring bifurcation, and limited medical testimony regarding Castro's brain injuries during the liability phase. The jury found that Castro did not fall from a scaffold. On appeal, the Appellate Division, Second Department, reversed the judgment, set aside the verdict, and granted a new, unified trial, holding that the trial court improvidently exercised its discretion. The court clarified that bifurcation is not absolutely required in the Second Department and that a unified trial was warranted here because the nature of Castro's injuries was inextricably intertwined with the issue of liability, making evidence of brain injuries probative as to how the incident occurred.