Mealey's (January 11, 2017, 11:27 AM EST) -- NEW ORLEANS — A federal district court did not abuse its discretion in bifurcating in a lawsuit arising from tornado damage because insureds’ extracontractual and punitive damages claims required the same showing on the part of their insurer, but their breach of contract claim did not, a Fifth Circuit U.S. Court of Appeals panel ruled Dec. 13 in an unpublished per curiam opinion (Edward and Rebecca Briggs v. State Farm, No. 16-60098, 5th Cir.; 2016 U.S. App. LEXIS 22101)....