R.C. 2323.51 Interpretation
In Fenley v. Bowman (Apr. 17, 2000), 4th Dist. No. 99CA51, 2000 Ohio App, the Fourth District Court of Appeals upheld an award of sanctions pursuant to R.C. 2323.51 on the grounds that the appellant had insufficiently pled her claim for slander per quod.
Noting that the complaint failed to identify any specific slanderous statements, and, instead, alleged only "distortions and falsehoods," the court found that the appellant's insufficiently pled complaint was not warranted under existing law and, thereby, supported the sanctions award under R.C. 2323.51.