“It’s déjà vu all over again.” Yogi Berra.
On December 14, 2016, the Supreme Court of Ohio handed down a merit decision in Simpkins v. Grace Brethren Church 2016-Ohio-8118. At issue in the case was an as-applied constitutional challenge to the caps on noneconomic tort damages set out in R.C. 2315.18(B). In another fractured