Simpkins v. Grace Brethren Church of Delaware, OhioAnnotate this Case
Jessica Simpkins and her father, Gene Simpkins, (together, Appellants) sued Grace Brethren Church of Delaware, Ohio for negligent hiring, retention, and supervision of Brian Williams, a senior pastor at Sunbury Grace Brethren Church who forced oral and vaginal intercourse with Simpkins, then a fifteen-year-old parishioner. The jury found that Simpkins was entitled to $3,651,378 in compensatory damages, which included past and future economic damages and past and future noneconomic damages. The trial court applied the cap in Ohio Rev. Code 2315.18(B)(2) to reduce Simpkins’s noneconomic damages from $3.5 million to $350,000. The court of appeals rejected Appellants’ constitutional challenges to section 2315.18(B)(2) as well as their argument that Simpkins’s noneconomic damages arose out of two occurrences for purposes of applying the damage caps. The Supreme Court affirmed, holding (1) section 2315.18(B) is constitutional as applied to the facts in this case; and (2) this case involved a single “occurrence” for purposes of applying the damage caps.