Lyme Land Conservation Trust, Inc. v. Platner

Summary

The court held that the trial judge was disqualified from presiding over a damages proceeding ordered after the judgment was partially reversed on appeal. A remand requiring new evidence and recalculation of damages constitutes a new trial for purposes of the disqualification statute, even though liability and other portions of the judgment were affirmed. The court therefore reversed the damages judgment, vacated related orders, and remanded for proceedings before a different judge; it did not reach the defendant’s remaining merits claims.