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· 10/13/2023

Ryan v. State Farm Mut. Auto Ins. Co.

Citations

  • 226 N.E.3d 500
  • 2023 Ohio 3731

Syllabus

The trial court properly bifurcated an insured's claims against his insurance company for breach of contract in providing uninsured motorist coverage and bad faith. However, the court erred as a matter of law in ordering the insurance company to immediately produce certain evidentiary materials in its claims file in discovery. The materials at issue were relevant only to the bad faith claim, and their disclosure undoubtedly would prejudice the insurance company's ability to defend against the uninsured motorist claim. The insured is not entitled to discovery of such materials until the underlying breach of contract claim is resolved. Judgment reversed and remanded.

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

  • concluding that “[n]othing in the Constitution obligates state courts to give mitigating circumstance instructions when no evidence is offered to support them”
  • “Nothing in the Constitution obligates state courts to give mitigating circumstantial instructions when no evidence is offered to support them.”
  • burden of proof of mitigating circumstances may be put on the defendant in a capital sentencing
  • “Once the defendant has been convicted fairly in the guilt phase of [a capital] trial, the presumption of innocence disappears.”
  • Walton establishes “that a State may require the defendant ‘to bear the risk of nonpersuasion as to the existence of mitigating circumstances.’ ”
  • “Once the defendant has been convicted fairly in the guilt phase of [a capital] trial, the presumption of innocence disappears.”

Source: CourtListener parenthetical corpus (CC0).

Judges: Huffman

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