Are Punitive Damages Capped by Statutory Limits on Torts When Case Involves Violation of Landlord/Tenant Contract?

Village Green of Beachwood, L.P., et al. v. Carlos Sivit, et al., Case no. 2013-0586

Eighth District Court of Appeals (Cuyahoga County)

ISSUES:

When a claim arises from an alleged breach of a duty created by a landlord-tenant contractual relationship, is a lawsuit to recover damages for injury to person or property a "tort action" as defined in R.C. 2315.21, which includes a cap on punitive damages?

Did the tenants prove that the cause of the damage was a danger of which the landlord had actual or subjective knowledge in order to recover punitive damages?

May a landlord be held liable under Ohio's landlord-tenant law for property defects that were concealed?