N.C. Gen. Stat. » Chapter 1D
NC General Statutes

N.C. Gen. Stat. § 1D-30 (2026)

Bifurcated trial

✓ current as of July 2026
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Upon the motion of a defendant, the issues of liability for compensatory damages and the amount of compensatory damages, if any, shall be tried separately from the issues of liability for punitive damages and the amount of punitive damages, if any. Evidence relating solely to punitive damages shall not be admissible until the trier of fact has determined that the defendant is liable for compensatory damages and has determined the amount of compensatory damages. The same trier of fact that tried the issues relating to compensatory damages shall try the issues relating to punitive damages. (1995, c. 514, s. 1.)

 

Notes of Decisions
Cited in 13 cases (5 in the last 5 years), 1999–2026 · leading case: Jones v. Harrelson & Smith Contractors, LLC, 670 S.E.2d 242 (N.C. Ct. App. 2008).
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Jones v. Harrelson & Smith Contractors, LLC, 670 S.E.2d 242 (N.C. Ct. App. 2008). · cites it 25× “Upon motion of H & S, the compensatory and punitive damages stages of the trial were bifurcated pursuant to N.C. Gen.Stat. § 1D-30 (2007). At the conclusion of Jones' evidence in the liability phase of the trial, H & S moved for a directed verdict on all issues.”
Haarhuis v. Cheek, 805 S.E.2d 720 (N.C. Ct. App. 2017). · cites it 16× “On appeal, Defendant argues that Plaintiff's questioning of the jury during voir dire was improper and violated her "due process right" to a bifurcated trial because it involved issues that would only be relevant to Plaintiff's punitive damage claim.”
Lindsey v. Boddie-Noell Enter., Inc., 555 S.E.2d 369 (N.C. Ct. App. 2001). · cites it 8× “N.C. Gen.Stat. § 1D-30 (1999) (emphasis added).”
Ward v. Beaton, 539 S.E.2d 30 (N.C. Ct. App. 2000). · cites it 6× “It is clear that evidence of a defendant's net worth may be considered by the jury in determining the amount of a punitive damages award.”
Joyce McKiver v. Murphy-Brown, LLC, 980 F.3d 937 (4th Cir. 2020). “We review a district court’s decision not to bifurcate a trial for abuse of discretion.”
Rhyne v. K-Mart Corp., 562 S.E.2d 82 (N.C. Ct. App. 2002). · cites it 2× “Pursuant to N.C. Gen.Stat. § 1D-30, the trial was bifurcated into compensatory and punitive damages stages.”
Watson v. Dixon, 511 S.E.2d 37 (N.C. Ct. App. 1999). · cites it 4× “We are well-aware of the recent change in North Carolina's Punitive Damages Statute, Chapter 1D of our General Statues, which requires that "[t]he same trier of fact that tried the issues relating to compensatory damages shall try the issues relating to punitive damages.”
Jones v. Harrelson & Smith Contractors, LLC, 638 S.E.2d 222 (N.C. Ct. App. 2006). · cites it 2× “Defendant moved to bifurcate the compensatory and punitive damages stages of the trial, pursuant to N.C. Gen.Stat. § 1D-30. At the conclusion of plaintiff's evidence in the liability phase of the trial, defendant moved for a directed verdict on all issues.”
Hull v. Brown (N.C. Ct. App. 2021). · cites it 2× “BROWN 2021-NCCOA-525 Opinion of the Court and all seek compensatory and punitive damages for all four claims, so the same jury must hear all four claims pursuant to N.C. Gen. Stat. § 1D-30 (2019) (stating “the issues of liability for compensatory damages and the amount of…”
Mathis v. Terra Renewal Servs., Inc. (W.D.N.C. 2021). · cites it 2× “Defendants argue that consideration of punitive damages should be separated from compensatory damages based on N.C. Gen. Stat. § 1D-30, and that separating the issues of liability and damages would avoid prejudice to the Defendant while avoiding inefficiency because most…”
Hull v. Brown (N.C. Ct. App. 2021). · cites it 2× “BROWN 2021-NCCOA-525 Opinion of the Court and all seek compensatory and punitive damages for all four claims, so the same jury must hear all four claims pursuant to N.C. Gen. Stat. § 1D-30 (2019) (stating “the issues of liability for compensatory damages and the amount of…”
Clements v. Arc Ncchrnc001, LLC (N.C. Ct. App. 2026). · cites it 2× “On 13 September 2024, Firebirds filed a motion to dismiss pursuant to Rule 12(b)(6), a motion to bifurcate pursuant to N.C. Gen. Stat. § 1D-30, and an answer asserting eight affirmative defenses.”
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