The following excerpt is from Smith-Downs v. City of Stockton, No. 2:10-cv-02495-CKD (E.D. Cal. 2019):
The court finds bifurcation is appropriate in this matter. While the court is mindful that that there is some potential overlap between evidence related to damages and evidence regarding plaintiffs' Fourteenth Amendment claims, the nature of the facts of this case and the threat of potential prejudice to plaintiffs strongly cautions towards bifurcation. The threat of prejudice is particularly conspicuous when the evidence consists of the prior bad acts or criminal history of a decedent. See Estate of Diaz v. City of Anaheim, 840 F.3d 592, 601 (9th Cir. 2016).
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