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Supreme Court of Ohio reverses $800,000 judgment in defamation case, rules caps on damages apply

By Charmaine Little | Jan 7, 2019

COLUMBUS, Ohio (Legal Newsline) – On Dec. 7, the Supreme Court of Ohio reversed an $800,000 judgment in compensatory damages in a defamation case.

The Supreme Court reversed the Court of Appeals' judgment regarding compensatory damages and remanded the case back to the trial court. The Supreme Court had to determine if a $250,000 cap on noneconomic losses should apply based on a state regulation.

"We hold that the statute unambiguously caps the noneconomic damages that can be recovered as a result of defamation, and we remand the case to the trial court for further proceedings," the ruling states.

After the case was heard in lower courts, which decided the cap didn’t apply, the Supreme Court had to determine if defamation is an injury to a person, which would subsequently conclude if the cap should be enforced.

The issue dates back to the plaintiff Ann Wayt’s days as a nurse with Affinity Medical - the health group that fired Wayt after an investigation over allegations of negligence. She ended up getting her job back.

When she returned to work, the ruling states one of her co-workers made a statement in front of several other nurses that the court order to have Wayt return to work didn’t mean that she should have gotten her job back or that she was even a "good nurse."

Wayt then filed a defamation lawsuit in the Stark County Court of Common Pleas and a jury awarded her $800,000 in compensatory damages and $750,000 in punitive damages. Affinity Medical filed a post-trial motion in an attempt to get the lower court to enforce the cap on noneconomic compensatory damages outlined in R.C. 2315.18(B)(2) and the cap on punitive damages in R.C. 2315.21(D) to lower the awarded amount. 

The trial court said the caps don’t work for injuries based on reputation, like defamation. Affinity Medical challenged it in an appellate court, which agreed with the trial court, leading Affinity Medical to appeal in the current court.

“We see no reason to overturn the well-established precedent that defamation is a ‘personal injury’ according to the plain meaning of the term,” the ruling states. 

Justice Pat Fischer authored the opinion and justices Sharon L. Kennedy, Judith L. French and R. Pat DeWine concurred.

Meanwhile, Justice Maureen O'Connor dissented altogether, joined by Terrence O’Donnell.

The dissenting argument was that defamation is an injury or loss of reputation and is not the same as an injury to a person, so the cap shouldn’t be applied. The dissenting judges pointed out that injury to a person means there as an obvious injury to their body that requires healing, while injury to a reputation exists in the heart and mind of others.

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