On October 8, 2014, the Supreme Court of Ohio handed down a merit decision in Bank of Am., N.A. v. Kuchta, 2014-Ohio-4275. In a 5-2 opinion written by Chief Justice O’Connor, for herself and Justices Lanzinger, O’Donnell, French, and Kennedy, the court answered the following certified conflict question in the negative:
“When a defendant