State Ex Rel. Atkins v. Burnside

569 S.E.2d 150, 212 W. Va. 74, 2002 W. Va. LEXIS 126
CourtWest Virginia Supreme Court
DecidedJune 27, 2002
Docket30510
StatusPublished
Cited by7 cases

This text of 569 S.E.2d 150 (State Ex Rel. Atkins v. Burnside) is published on Counsel Stack Legal Research, covering West Virginia Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State Ex Rel. Atkins v. Burnside, 569 S.E.2d 150, 212 W. Va. 74, 2002 W. Va. LEXIS 126 (W. Va. 2002).

Opinion

PER CURIAM.

The Petitioners, as plaintiffs 1 in consolidated chemical exposure cases, seek a writ of mandamus requiring the Circuit Court of Raleigh County to make findings of fact and conclusions of law in support of its discovery management plan. The Petitioners further seek a writ of prohibition requiring the lower court to vacate the portion of its discovery management plan which consolidates twenty-three cases for discovery purposes. Having thoroughly evaluated the record, briefs, and arguments of counsel, we find that the lower court’s findings of fact and conclusions of law provide sufficient basis for consideration by this Court. We therefore refuse the Petitioners’ request for a writ of mandamus requiring additional findings of fact and conclusions of law.

With regard to the discovery management plan and the consolidation of the twenty-three cases for discovery purposes in reverse bifurcation fashion, we grant the requested writ of prohibition, as moulded, with express directions as stated herein.

*80 I. Facts and Procedural History

In State ex rel. Crafton v. Burnside, 207 W.Va. 74, 528 S.E.2d 768 (2000), involving these same chemical exposure civil actions, this Court addressed some of the discovery matters implicated in the present case. In Crqfton, this Court explained that the lower court had adopted a case management plan, based upon the consent of the plaintiffs and defendants, which would permit the eases to be tried in a reverse bifurcation manner, 2 allowing issues of damages and causation to be tried prior to issues of liability of the multiple defendants. Upon advice of new legal counsel, the plaintiffs sought reversal of the reverse bifurcation plan. The lower court denied the motion, and the plaintiffs filed a petition for writ of prohibition with this Court, seeking to prevent implementation of the case management plan of reverse bifurcation. This Court granted the writ of prohibition, based upon the withdrawal of consent by the plaintiffs, and remanded the issue to the lower court for de novo review of whether the plan of reverse bifurcation should be utilized in this case. 207 W.Va. at 79, 528 S.E.2d at 773.

Particularly relevant to the present inquiry, this Court in Crafton also strongly cautioned the lower court that, in its de novo review on remand, the benefits and detriments of the reverse bifurcation methodology should be carefully weighed. Specifically, this Court stated as follows:

In the instant case, the plaintiffs sought to be relieved of the effect of their initial counsel having stipulated, due to his undisputed inexperience and ignorance, to a trial procedure that is contrary to that which is enjoyed by essentially all other ordinary civil litigants in West Virginia. Moreover, the economy and fairness of the sort of procedure that was agreed to by the plaintiffs’ initial counsel is the subject of serious dispute.
In light of the foregoing principles, we conclude that the plaintiffs should have been allowed to withdraw their consent to the reverse bifurcation procedure, and that the circuit court abused its discretion in failing to allow them to do so. On the limited record before us, we cannot rule on the issue of whether, absent the consent of the plaintiffs to “reverse bifurcation,” the circuit court should adopt that procedure. The issue of possible reverse bifurcation should be addressed by the circuit court de novo, making any record that may be necessary, without giving any effect to the plaintiffs’ previous stipulation to the procedure.

Id. at 78-79, 528 S.E.2d at 772-73 (footnotes omitted). In footnote four of Crafton, this Court discussed the fact that the methodology of reverse bifurcation has not been the traditional practice of litigants in this State, noting that “[o]ur historic preference for unitary trials is clear in our jurisprudence.” Id. at 78 n. 4, 528 S.E.2d at 772 n. 4. In explaining that reverse bifurcation has not been universally embraced, this Court cited Walker Drug Co. v. La Sal Oil Co., 972 P.2d 1238 (Utah 1998), in which the Utah court declared that reverse bifurcation is rare and “drastic” technique. Crafton, 207 W.Va. at 79 n. 5, 528 S.E.2d at 773 n. 5 (quoting Walker Drug, 972 P.2d at 1245). In Crqfton, this Court also directed the lower court’s attention to the following authorities on the issue of the legitimacy of the reverse bifurcation method:

See generally Roger H. Transgrud, “Join-der Alternatives in Mass Tort Litigation,” 70 Cornell L.Rev. 779, 827-29 (1985). See also Sandra A. Smith, “Polyfurcation and the Right to a Civil Jury Trial: Little Grace in the Woburn Case,” 25 Boston College Env.Aff.L.Rev. 649, 685 (1998) (focusing on the lawsuit that underlies the book and movie, “A Civil Action” and discussing how inappropriate “polyfurcation” *81 can be “particularly harmful to injured parties” in the toxic tort context). See also J.M. Granholm and William J. Richards, “Bifurcated Justice: How Tidal-Splitting Devices Defeat the Jury’s Role,” 26 U. Toledo L.Rev. 505 (1995).

Id. at 79 n. 5, 528 S.E.2d at 773 n. 5. This Court’s statements in Crafton were very detailed regarding the fact that this case had not been referred by the lower court to the Mass Litigation Panel, pursuant to Tidal Court Rule 26.01(b)(1). This Court reasoned:

Many of the factors that have been suggested as supporting a reverse bifurcated trial procedure, such as clearly established liability that would make a second phase of the trial unlikely, demonstrated absence of prejudice to the plaintiffs, lack of duplica-tive witnesses, and a great number of plaintiffs or defendants- — are not present in the instant case.

Id. at 79 n. 5, 528 S.E.2d at 773 n. 5.

On remand from the directives of this Court in Crafton, the lower court entered an order stating that the cases of the original nine plaintiffs would be consolidated with the additional fourteen plaintiffs for discovery purposes and that discovery would be conducted through the process of reverse bifurcation, with damages and causation considered prior to issues of liability. 3 The Petitioners now bring this writ of mandamus seeking findings of fact and conclusions of law and writ of prohibition seeking to prevent the consolidation of all twenty-three plaintiffs for discovery purposes.

II. Standard of Review

The Petitioners seek writs of mandamus and prohibition, contending that the lower court exceeded its legitimate powers in issuing the discovery management plan.

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Cite This Page — Counsel Stack

Bluebook (online)
569 S.E.2d 150, 212 W. Va. 74, 2002 W. Va. LEXIS 126, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-atkins-v-burnside-wva-2002.