Bishop v. Grdina

The issues presented in this appeal are: (1) whether the $500,000 punitive damage award as to the 1977 sales contract was properly stricken; and (2) whether the total punitive damages awarded was properly decreased pursuant to Civ. R. 54(C). We affirm on both issues.

I

This court stated in paragraph one of the syllabus in Richard v. Hunter (1949), 151 Ohio St. 185 [39 O.O. 24], that “[e]xemplary or punitive damages may not be awarded in the absence of proof of actual damages.” This position was recently upheld in Seasons Coal Co. v. Cleveland (1984), 10 Ohio St. 3d 77, where the court states at…