Niskanen v. Giant Eagle, Inc.

*487Moyer, C.J.

I

{¶ 1} This appeal presents three issues for our review: (1) whether punitive damages may be awarded when a plaintiff pursues only negligence causes of action and does not receive any compensatory damages, (2) whether a defendant may claim self-defense as an affirmative defense to a negligence cause of action, and (3) whether a plaintiff may bring a cause of action for undue restraint under R.C. 2935.041.

{¶ 2} For the following reasons, we reverse the judgment of the court of appeals and hold that punitive damages are not available in negligence causes of action unless the…