With Josephine Noble, Natalie Stevens
On July 3, 2012, the Ohio Supreme Court directed the Eighth District Court of Appeals to apply the Ohio Supreme Court’s ruling in Havel v. Villa St. Joseph, 131 Ohio St.3d 235 (2012) that, upon motion of a party, Ohio Revised Code § 2315.21(B) requires a trial court to bifurcate claims for compensatory and punitive damages, to a retaliation claim asserted under Ohio Revised Code § 4112. See Luri v. Republic Servs., Inc., et al., Slip Opinion No. 2012-Ohio-2914.