Is Denial of Motion to Bifurcate Trial of Suit Seeking Both Compensatory, Punitive Damages a 'Final Order'?
When Motion Refers to 2005 Tort Reform Provision
8th District Court of Appeals (Cuyahoga County)
ISSUE: When the plaintiff in a civil lawsuit seeks both compensatory and punitive damages from a defendant, and the defendant files a motion citing R.C. 2315.21(B) and asking the trial court to bifurcate the plaintiff's claims, is the court's denial of the motion to bifurcate without stating a reason a "final order" subject to immediate review by a court of appeals under R.C. 2505.02(B)(6) and/or R.C. 2505.02(B)(4)?