275:163 U.S. Supreme Court rules that prisoner placed in disciplinary segregation following charges of misconduct was not entitled to due process procedural protections; shift in focus in determining whether state regulations create a constitutionally protected liberty interest Sandin v. Conner, 115 S.Ct. 2293 (1995).
     Punitive damages are not, per se, a violation of due process, but Supreme Court indicates that "extreme results" may be "unacceptable" under due process Pacific Mut Life Ins Co v. Haslip, 111 S.Ct. 1032 (1991).
     Ohio Supreme Court holds that civil rights lawsuit for allegedly harassive towing resulting only in economic loss may not be brought, absent claim of inadequate state law remedy St Clair Corp v. City of Cleveland, 550 N.E.2d 456 (Ohio, 1990).