Plaugher v. Oniala, 2011 Ohio 1207

Plaintiff Monica Plaugher was injured in a December 10, 2007 motor vehicle collision with defendant Ethan Knowles.
Knowles allegedly accelerated through a red light and engaged in horseplay with teenage passengers at the time of the crash.
Plaintiffs asserted a tort claim for compensatory damages and alleged conduct supporting punitive damages.
Knowles moved on July 26, 2010 to bifurcate punitive damages from liability and compensatory claims; plaintiffs opposed.
The trial court denied the bifurcation motion on August 2, 2010.
Knowles appealed the denial to the Stark County Court of Appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does RC 2315.21(B) conflict with Civ.R. 42(B) and violate the Ohio Constitution?	Knowles argues the statute mandates bifurcation, conflicting with rule-based discretion.	Knowles contends the statute is constitutional and supersedes procedural rules.	Statute unconstitutional; rule prevails; denial of bifurcation affirmed.

Myers v. Brown, 2011-Ohio- (Ohio 2011) (court held R.C. 2315.21(B) unconstitutional to mandate bifurcation)
Hanners v. Ho Wah Genting Wire & Cable, 2009-Ohio-6481 (Ohio) (conflict between statute and Civil Rule; constitutionality at issue)
Havel v. Villa St. Joseph, 2010-Ohio-5251 (Ohio) (statute evaluated as procedural vs. substantive)
State ex rel. Loyd v. Lovelady, 2006-Ohio-161 (Ohio) (constitutional separation of powers; rules prevail over conflicting statutes in procedural matters)
State ex rel. Sapp v. Franklin County Court of Appeals, 2008-Ohio-2637 (Ohio) (substantive vs. procedural distinction governs conflicts with Supreme Court Rules)
Norfolk Southern R.R. v. Bogle, 115 Ohio St.3d 455 (2007-Ohio-5248) (procedural rules vs. statutory provisions; proper framework for bifurcation inquiry)
Jones v. Erie Railroad Co., 106 Ohio St. 408 (1922) (early articulation of procedural vs. substantive-law distinction)