Justia Civil Procedure Opinion Summaries

Marcus Pryor applied to the Ohio Department of Job and Family Services (ODJFS) for unemployment compensation. The director of ODJFS concluded that Pryor was ineligible for benefits. A hearing officer with the Unemployment Compensation Review Commission affirmed. The Commission denied Pryor’s request to review the hearing officer’s findings. Pryor filed an appeal in the common pleas court naming the director of ODJFS as the appellee but failing to name the Army, Pryor’s former employer, as a party to his appeal. The common pleas court dismissed the appeal, finding that because Pryor failed to name the Army was an interested party, his notice of appeal did not comply with Ohio Rev. Code 4141.282(D), thus depriving the court of subject-matter jurisdiction. The court of appeals reversed the common pleas court’s dismissal of Pryor’s appeal and reinstated Pryor’s administrative appeal in the common pleas court, ruling that Pryor’s failure to name the Army was not a jurisdictional defect. The Supreme Court reversed, holding (1) the naming of interested parties is not a jurisdictional requirement under section 4141.282; but (2) the Commission failed to comply with the procedural requirements in section 4141.282(D), and therefore, Pryor’s time to appeal the Commission’s decision never started to run. Remanded. View "Pryor v. Dir., Ohio Dep’t of Job & Family Servs." on Justia Law

Sarunas Abraitis, the former executor of his mother’s estate, applied to admit his mother’s will to probate. The will provided that if Abraitis’s father predeceased his mother, her entire estate would be divided equally between Abraitis and his brother, Vytautas. The matter was assigned to Judge Laura Gallagher. While the estate was being administered, Vytautas died. Abraitis subsequently filed an application to probate a different, later will that his mother executed and that bequeathed to him the entire estate. Vytautas’s former wife, Vivian, filed a complaint to contest the later will. The action was also assigned to Judge Gallagher. Abraitis filed two actions in prohibition alleging that Judge Gallagher lacked jurisdiction. As grounds for the writ, Abraitis referred to collateral proceedings regarding his mother’s guardianship and federal and state tax proceedings, arguing that because none of the parties objected or moved to intervene in the tax cases, the probate court was precluded from hearing any matter concerning the estate. The court of appeals dismissed Abraitis’s complaints in prohibition. The Supreme Court affirmed, holding that Abraitis had an adequate remedy in the ordinary course of the law and that Judge Gallagher did not patently and unambiguously lack jurisdiction over the probate court action. View "State ex rel. Abraitis v. Gallagher" on Justia Law

Chester Township and its trustees (collectively, Relators) sought to prohibit Judge Timothy Grendell (Respondent) from issuing or enforcing rulings against them in the case that created the Chester Township Park District, arguing that the probate court lacked subject matter jurisdiction to issue orders attempting to correct activities by the park-district commissioners and the township trustees that frustrated the purpose of the original probate court order creating the park district. The probate court, in turn, asserted that it had continuing subject matter jurisdiction over the case creating the park district. The Supreme Court denied the writ, holding that the township trustees failed to show that the probate court patently and unambiguously lacked jurisdiction to issue the orders at issue. View "State ex rel. Chester Twp. v. Grendell" on Justia Law

This action raised several challenges to recently enacted legislation and administrative rules related to gambling in the state. Plaintiffs filed an amended complaint against several state entities challenging the constitutionality of video lottery terminals and H.B. 1, the act that authorized them, and legislative actions that related to Ohio’s four casinos, particularly H.B. 277 and H.B. 519. Lastly, Plaintiffs claimed that Ohio Const. art. XV, 6, H.B.1, H.B. 277, and H.B. 519 violate equal protection by granting a monopoly to the gaming operators whom the state approved. The trial court granted the state’s motion to dismiss the action for lack of standing and for failure to state claim, concluding that none of the plaintiffs had standing. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) Plaintiffs failed to establish that they had organizational standing or standing based on their status as individuals experiencing the negative effects of gambling, parents and a teacher of public-school students, and contributors to the commercial-activity tax; and (2) one plaintiff, however, sufficiently alleged standing to survive Defendants’ motion to dismiss his equal protection claim. Remanded. View "State ex rel. Walgate v. Kasich" on Justia Law

Appellant made a request for public records and information based on events surrounding the arrest for another individual. When the Ohio Department of Public Safety (ODPS) denied portions of the request, Appellant filed this action in mandamus. The court of appeals dismissed the petition for mandamus, concluding that ODPS had properly denied portions of Appellant’s request. The court subsequently denied Appellant’s application for reconsideration and en banc consideration, concluding that the requests were a nullity. The Supreme Court affirmed, holding that an application for reconsideration or for en banc consideration under the appellate rules cannot be made in an original action. View "State ex rel. Ziegler v. Ohio Dep’t of Pub. Safety" on Justia Law

Appellant filed a public-records request under the Ohio Public Records Act for the personnel records of six employees of the West Licking Joint Fire District. Less than three business days later, Appellant filed a complaint for a writ of mandamus in the court of appeals. The district’s counsel completed the review of the requested records the same day, and the district sent the documents to Appellant that afternoon. The district did not become aware of Appellant’s complaint until the next day. The court of appeals concluded that the records were produced in a reasonable amount of time and that Appellant had engaged in frivolous conduct. The Supreme Court affirmed in part but found that the court of appeals abused its discretion when it failed to hold a show-cause hearing before finding that Appellant had engaged in frivolous conduct. On remand, the court of appeals held the required hearing and found that Appellant engaged in frivolous conduct, thus awarding attorney fees. The Supreme Court affirmed, holding that the court of appeals did not abuse its discretion in finding that the continuation of unnecessary discovery after the requested records were provided was frivolous conduct. View "State ex rel. Davis v. Metzger" on Justia Law

Plaintiff, individually and on behalf of her daughter, filed a civil suit against Defendant for assault, false imprisonment, emotional distress, and loss of consortium. Plaintiff requested compensatory and punitive damages. After Defendant failed to respond to the complaint, the trial court entered a default judgment against her. Before the damages hearing, Defendant died. The administrator of Defendant’s estate was substituted as a party. After a hearing, the trial court awarded compensatory damages to Plaintiff’s two daughters and concluded that punitive damages could not be properly awarded against the estate of a deceased tortfeasor. The Court of Appeals reversed, concluding that Ohio law permits an award of punitive damages against a deceased tortfeasor. The Supreme Court affirmed, holding that a punitive damages award is available in the limited circumstances presented in this case. Remanded to the trial court for a hearing on punitive damages and attorney fees. View "Whetstone v. Binner" on Justia Law

Appellant was granted a default judgment against Bank of America and filed a praecipe for a writ of execution. BAC Field Services filed a motion to stay the execution of judgment and a motion for relief from judgment. The trial court granted the motions. The court of appeals reversed and remanded the case with instructions for the trial court to clarify its reasoning. Thereafter, Appellant moved the trial court to reinstate the default judgment. When the court had not ruled on the motion, Appellant filed this action requesting writs of prohibition barring the trial court from vacating the default judgment and barring BAC from appearing in the case. The court of appeals denied the writs. After Appellant appealed, the trial court again vacated the default judgment and responded to the court of appeals’ instruction to clarify its reasoning. The Supreme Judicial Court (1) declared the petition for a writ of procedendo moot because the trial court had issued a decision clarifying its reasons for vacating the default judgment; and (2) affirmed the court of appeals’ judgment denying Appellant’s petition for writs of prohibition because the court did not patently and unambiguously lack jurisdiction to proceed. View "State ex rel. Haley v. Davis" on Justia Law

Gabriella Moir was the plaintiff in the underlying divorce case. Judge Mary Kovack, the only judge in the Medina County Domestic Relations Court, recused herself from the case. Acting in her capacity as the administrative judge of that court, Judge Kovack subsequently issued orders assigning magistrates to the visiting judge, Judge Carol Dezso of Summit County Domestic Relations Court, for the purpose of presiding over the divorce. Moir brought this action for a writ of prohibition against Judge Kovack and Judge Dezso, as well as the two courts and one of the assigned magistrates, asserting that the two judges lacked jurisdiction to assign magistrates in the case. The Supreme Court granted a peremptory writ as to Judge Kovack, holding (1) because Judge Kovack recused herself based on a potential conflict of interest, she was without jurisdiction to assign magistrates in the case; and (2) Judge Dezso as the appointed judge may assign magistrates to help her hear the case. View "State ex rel. Moir v. Kovack" on Justia Law

Craig Conley faxed a letter to Judge Dixie Park requesting full and legible copies of documents from the court’s electronic docket. Judge Park returned the request, stating that the court did not accept faxed filings without the court’s prior approval. Conley responded that his request was not a filing but a public-records request. Conley subsequently filed this action requesting a peremptory or alternative writ of mandamus ordering Judge Park to provide the copies of the requested records. Before Judge Park responded to the complaint and before twenty-eight days had elapsed the court of appeals issued a peremptory writ and closed the case. Judge Park filed a motion for relief from judgment and then filed an appeal to the Supreme Court. The court of appeals concluded that, because of the appeal, it was without jurisdiction to rule on the motion for relief from judgment unless the case was remanded. Conley moved the Supreme Court to remand the case. The Supreme Court reversed, holding that the court of appeals acted prematurely before allowing Judge Park to answer or otherwise respond to the complaint. Remanded. View "State ex rel. Conley v. Park" on Justia Law