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Brown v. Brooklyn Union Gas Company

Appellate Division of the Supreme Court of New York, Second Department
Feb 1, 1988
137 A.D.2d 479 (N.Y. App. Div. 1988)

Opinion

February 1, 1988

Appeal from the Supreme Court, Kings County (Adler, J.).


Ordered that the order is reversed, without costs, the motion is denied, and venue of the personal injury action is returned to Kings County.

The complaint in the personal injury action alleges injuries to two infant plaintiffs as a result of a gas explosion at a Brooklyn dwelling on February 10, 1970. The complaint originally contained five claims of wrongful death alleged to have resulted from the same explosion. The wrongful death causes of action were dismissed as barred by the Statute of Limitations. The plaintiffs then commenced legal malpractice actions against the defendants attorneys.

Although the personal injury and legal malpractice actions involve "a common question of law or fact" as required by CPLR 602 (a), under the facts of this case consolidation was an improvident exercise of discretion, since a consolidation of this action would be unduly prejudicial to the appellant's right to a fair trial. Accordingly, we reverse.

A trial of the legal malpractice actions would necessarily involve detailed evidence concerning the deaths of the five people and the damages derived therefrom, which evidence might not be admissible at the trial of the personal injury action. Furthermore, the actions involve many dissimilar issues which may confuse the jury. "[S]eparate trials will enable the juries to focus on the factual issues presented as to each [case]" (Shackleford v Mills, 110 A.D.2d 630). Therefore, the order consolidating the actions is reversed and, due to the absence of any motion by a party to the venue of the personal injury action for change of venue, the venue of the personal injury action is ordered returned to Kings County (see, CPLR 509, 510).

We further recommend, for reasons of judicial economy, that the trial of the personal injury action precede the trial of the legal malpractice actions. Bracken, J.P., Kunzeman, Spatt and Sullivan, JJ., concur.


Summaries of

Brown v. Brooklyn Union Gas Company

Appellate Division of the Supreme Court of New York, Second Department
Feb 1, 1988
137 A.D.2d 479 (N.Y. App. Div. 1988)
Case details for

Brown v. Brooklyn Union Gas Company

Case Details

Full title:LEONARD J. BROWN, Individually and as Administrator of the Estate of…

Court:Appellate Division of the Supreme Court of New York, Second Department

Date published: Feb 1, 1988

Citations

137 A.D.2d 479 (N.Y. App. Div. 1988)

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