In O'Connell v. Chesapeake & O. R. Co.., 58 Ohio St. 3d 226, 236, 569 N.E.2d 889 (1991), the Ohio Supreme Court adopted the "same juror" rule in comparative negligence cases so that only those jurors who find liability (i.e., breach of duty and proximate cause) may participate in the decision apportioning liability among the parties. The Court in O'Connell examined the law of other jurisdictions, describing two distinct lines of cases. The Court cited several states that followed the same juror rule because "a juror's finding as to whether liability exists is so conceptually and logically connected with apportioning fault that inconsistent answers to the two questions render that juror's vote unreliable and thus invalid." Id. at 233. Therefore, only jurors who agreed with the majority regarding liability may participate in the apportioning of that liability in a comparative negligence case. Id. The Court also cited several states that followed the "any majority" rule. Id. at 233. Under this rule, there is no requirement of individual juror consistency in voting. Id. at 233-35. Therefore, once three-fourths of the jury has found a party liable, dissenting jurors may "accept the majority's finding . . . and participate in apportioning liability." Id. at 234 (quoting Juarez v. Super. Ct. of Los Angeles, 31 Cal. 3d 759, 768, 183 Cal. Rptr. 852, 647 P.2d 128 (1982)). The Ohio Supreme Court held that, in comparative negligence cases, the same juror rule applies to require individual voting consistency between interrogatory responses finding liability and apportioning it. O'Connell, 58 Ohio St. 3d at 236. The Court explained that it would be "illogical to require, or even allow, a juror to initially find a defendant has not acted causally negligently, and then subsequently permit this juror to assign some degree of fault to that same defendant." Id. at 235. The Court described "the allocation of fault" as a "method through which a juror clarifies his or her finding that a party is causally negligent for the injury sustained." Id. at 236. On that basis, the Court in O'Connell held the verdict for the defendant invalid because less than the requisite three-fourths of the jury had agreed that the Plaintiff was more than fifty-percent liable for her own injuries. Id. at 237. The Ohio Supreme Court did not adopt a strict application of the same juror rule in all cases. In fact, the Court pointed out in O'Connell that it was not willing to "extend its holding to reach" the application of the rule to "a jury's determinations as to liability and damages" as other jurisdictions had done. Id. at 232 n.3. The Court emphasized that the same juror rule "applies only to cases in which the answers are interdependent, not where they are separate and independent" like those of liability and damages. Id. at 233 (quoting Veberes v. Knappton Corp., 92 Ore. App. 378, 759 P.2d 279, 280 (Or. Ct. App. 1988)). A juror could logically find the defendant was not liable, but agree that the plaintiff's damages total a certain amount. It is, however, illogical for a juror to find the defendant was not liable, yet sign a general verdict finding against him and awarding damages to the plaintiff.