Sanders v. Clark
2016 Ohio 7267
| Ohio Ct. App. | 2016Background
- Sanders sued Clark in the Trumbull County Court of Common Pleas for invasion of privacy over publication of Sanders's private affairs.
- Default judgment was entered in Sanders's favor; damages were reserved for a damages hearing before a magistrate.
- The magistrate awarded $127.50 actual damages (lost wages) and $5,000 punitive damages, finding conscious disregard for Sanders's rights.
- Sanders objected, arguing the magistrate erred by not awarding noneconomic damages such as shame and emotional distress.
- The trial court adopted the magistrate's decision despite Sanders's objection and without a transcript of the magistrate proceedings, noting the transcript was not filed.
- The appellate court held the award for punitive damages exceeded statutory limits and remanded to assess compensatory noneconomic damages and adjust punitive damages accordingly.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the trial court abuse its discretion by adopting the magistrate's damages decision in full? | Sanders contends the magistrate failed to award noneconomic damages. | Clark argues the magistrate’s decision should be adopted as filed if supported by the record. | Appellate court: yes, abuse; remand for compensatory noneconomic damages and possible punitive adjustment. |
| Is noneconomic damages recoverable in invasion of privacy without proof of special damages? | Sanders asserts damages for shame and emotional distress should be awarded. | Clark argues damages were properly limited to the magistrate's findings. | Invasion of privacy allows noneconomic damages; the magistrate erred by not awarding compensatory noneconomic damages. |
| Do punitive damages comply with statutory caps when compensatory damages are minimal? | Sanders contends punitive damages can stand if justified by the conduct. | Clark argues punitive damages must align with statutory limits relative to compensatory damages. | Punitive damages exceed RC 2315.21 limits relative to compensatory damages; remand to adjust. |
Key Cases Cited
- LeCrone v. Ohio Bell Tel. Co., 120 Ohio App. 129 (10th Dist.1963) (invasion of privacy damages may include noneconomic harm)
- Reitz v. Giltz & Assocs., 11th Dist. Trumbull No. 2005-T-0126 (2006-Ohio-4175) (standard for damages review in torts; abuse of discretion)
- Stewart v. Hickory Hills Apts., 9th Dist. Medina No. 14CA0038-M (2015-Ohio-5046) (transcript requirement for objections to magistrate findings)
- Walker v. Lou Restoration, 9th Dist. Summit No. 26236 (2012-Ohio-4031) (review of magistrate decisions when no transcript)
- Salaben, In re Guardianship of, 11th Dist. Ashtabula No. 2008-A-0037 (2008-Ohio-6989) (abuse of discretion review standards for guardianship decisions)
- Preston v. Murty, 32 Ohio St.3d 334 (1987) (purpose of punitive damages and deterrence rationale)
- Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (abuse of discretion standard in domestic relations and torts)
- Columbus Finance, Inc. v. Howard, 42 Ohio St.2d 178 (1975) (distinction between compensatory and punitive damages)