Berube v. Richardson

TIM McCORMACK, J.:

{¶ 1} Plaintiff-appellant Judy Berube appeals from the trial court's award of punitive damages in connection with the court's granting of Berube's motion for default judgment against the defendant, Matthew Richardson. For the reasons that follow, we reverse and remand.

Procedural History and Substantive Facts

{¶ 2} On March 4, 2015, Berube filed a complaint against Matthew Richardson, d.b.a. Tazmainian Repair, Inc., alleging violations of Ohio's Consumer Sales Protection Act ("CSPA"), breach of contract, breach of warranty, failure to perform in a workmanlike manner, civil…