On February 15, 2012, the Supreme Court of Ohio issued a decision in Havel v. Villa St. Joseph,  2012-Ohio-552.  In a 5-2 decision (Chief Justice O’Connor concurred in judgment only) written by Justice O’Donnell, the Court upheld the constitutionality of  R.C. 2315.21(B), the mandatory bifurcation provision of the punitive damages statute. This statute, as

On February 15, 2012, the Supreme Court of Ohio issued a decision in Havel v. Villa St. Joseph,  2012-Ohio-552.  In a 5-2 decision (Chief Justice O’Connor concurred in judgment only) written by Justice O’Donnell, the Court upheld the constitutionality of  R.C. 2315.21(B), the mandatory bifurcation provision of the punitive damages statute. This statute, as