Second District Court of Appeals (Montgomery County)

ISSUES:

-To establish that a police officer's conduct was a proximate cause of injuries to innocent third parties stemming from a high-speed pursuit, does a plaintiff need to prove the officer's conduct was "extreme or outrageous"?

-Based on Ohio's "no proximate-cause rule," is a pursuing police officer's conduct extreme and outrageous when the officer violates the pursuit policy of his or her law enforcement agency?