Ptselnikov v. Artisan and Truckers Casualty Company, 1:24-cv-01030

Plaintiff Aida Ptselnikov sued her insurer, Artisan and Truckers Casualty Company, for injuries sustained in a vehicle collision involving an unidentified driver.
Plaintiff alleges breach of contract, common law bad faith, and statutory unreasonable delay or denial of insurance benefits under Colorado law.
Defendant disputes Plaintiff's entitlement to uninsured motorist benefits, alleging Plaintiff was at least 50% at fault, and that her injuries were pre-existing or unrelated.
Defendant moved to bifurcate (separate) the trial into two: one for fault/liability and one for damages and bad faith; Plaintiff opposed, arguing overlap in issues and inefficiency.
The matter was removed to federal court; the motion to bifurcate is fully briefed and addressed here.

Issue	Plaintiff’s Argument	Defendant’s Argument	Held
Bifurcation under Rule 42(b): Convenience	One trial is more convenient, avoids duplicative effort	Initial fault trial will be quicker and more efficient	Denied: single trial is better
Judicial economy	Evidence overlaps; two trials add cost and delay	Damages/bad faith trial would be more costly if not split	Denied: no clear efficiency gain
Separability of issues	Claims stem from same facts and are intertwined	Fault and damages/bad faith issues are distinct	Denied: issues not separable
Potential unfairness/prejudice	Bifurcation hurts ability to present unified case	Joint trial unfairly conflates evidence, risks prejudice	Denied: prejudice is manageable

Green Constr. Co. v. Kan. Power & Light Co., 1 F.3d 1005 (10th Cir. 1993) (establishing broad discretion of district courts in bifurcation)
Easton v. City of Boulder, Colo., 776 F.2d 1441 (10th Cir. 1985) (court's consideration for bifurcation under Rule 42(b))
Flickinger v. Ninth Dist. Prod. Credit Ass’n of Wichita, 824 P.2d 19 (Colo. App. 1991) (bad faith claim may exist independently of contract claim)