Is Punitive Damages 'Cap' the Maximum Amount Recoverable From Each Defendant, or From All Defendants Collectively?

Where Jury Finds Each of Multiple Defendants Subject to Punitive Damages

Ronald Luri v. Republic Services, Inc., et al., Case no. 2011-1120

Eighth District Court of Appeals (Cuyahoga County)

ISSUE: When a jury awards the plaintiff in a civil lawsuit compensatory damages for which multiple defendants are jointly and severally liable, and also finds that each defendant is subject to punitive damages, does the state law capping punitive damages at "two times the amount of the compensatory damages awarded to the plaintiff from that defendant," allow a punitive damage award against each defendant of two times the total compensatory damages, or does the cap limit the punitive damages recoverable from all the defendants collectively to a total of two times the plaintiff's compensatory damages?