Galayda v. Lake Hosp. Systems, Inc

The Ohio Supreme Court in Galayda v. Lake Hosp. Systems, Inc. (1994), 71 Ohio St.3d 421, 428, 1994 Ohio 64, 644 N.E.2d 298, held that R.C. 1343.03(C) is constitutional. In Galayda, the Ohio Supreme Court held that Ohio's prejudgment interest statute does not violate the right to a jury trial for several reasons. First, the Court found "the potential application of R.C. 1343.03 in no way precludes a defendant from insisting on exercising his right to trial by jury nor does it 'create a financial barrier that prevents a party from taking his case to a jury,'" Id. at 427, quoting Kuenzer v. Teamsters Union Local 507 (1981), 66 Ohio St.2d 201, 203, 20 O.O.3d 205, 420 N.E.2d 1009, fn. 6. Second, the Court found that R.C. 1343.03 does not impose a penalty upon defendants for having exercised their right to a jury where prejudgment interest is awarded against them, and that, actually the prejudgment interest statute is "wholly compensatory in nature." Galayda at 427-428.