Justia Ohio Supreme Court Opinion Summaries

Articles Posted in Business Law
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The Supreme Court affirmed the opinion of the court of appeals affirming the decision of the trial court to grant summary judgment in favor of Defendants in this complaint alleging misappropriation of trade secrets, tortious interference with business contacts, tortious interference with business relationships, and conversion, holding that there was no error.Plaintiff, Hanneman Family Funeral Home and Crematorium, purchased a funeral home but did not retain the funeral home's director, Patrick Orians. Orians accepted employment at another funeral home, Chiles-Laman Funeral & Cremation Services, and used Plaintiff's customer information to solicit business for Chiles-Laman. Plaintiff sued Orians and Chiles-Laman (collectively, Defendants). The trial court entered summary judgment in favor of Defendants, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) the information at issue was not protected by the Ohio Uniform Trade Secrets Act as a trade secret; and (2) Plaintiff's tort claims were preempted by the Ohio Uniform Trade Secrets Act. View "Hanneman Family Funeral Home & Crematorium v. Orians" on Justia Law

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The Supreme Court vacated the judgment of the court of appeals in this case challenging the constitutionality of the Ohio Liquor Control Commission's emergency rule that was adopted as part of the state's initial response to the COVID-19 pandemic, holding that this appeal and the underlying case were moot.The Commission cited Appellant for violating Rule 80, which was adopted through the emergency procedures prescribed under Ohio Rev. Code 119.03(G). Appellant appealed the order and then initiated a separate civil action for declaratory judgment challenging the constitutionality of the rule. Rule 80 then expired. The trial court dismissed the declaratory judgment action because of the pending administrative appeal. The appellate court affirmed. The Supreme Court vacated the court of appeals' judgment, holding that this case was moot. View "Highland Tavern, L.L.C. v. DeWine" on Justia Law

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The Supreme Court reversed the opinion of the court of appeals affirming the judgment of the trial court in favor of Appellee on his claims for conversion and unjust enrichment, holding that the trial court erred in denying Appellant's motion for a directed verdict on the conversion and unjust enrichment claims.Appellee filed suit against Appellant and others, asserting claims for breach of fiduciary duty, conversion, civil conspiracy, and unjust enrichment. During trial, Appellant moved for a directed verdict on Appellee's conversion and unjust-enrichment claims. The trial court denied the motion. Thereafter, the jury returned verdicts against Appellant on the conversion and unjust enrichment claims. The court of appeals affirmed. The Supreme Court reversed, holding (1) there was insufficient evidence as a matter of law to support Appellee's claims of conversion and unjust enrichment against Appellant; and (2) therefore, the trial court erred in denying Appellant's motion for a directed verdict on these claims. View "Bunta v. Superior VacuPress, LLC" on Justia Law

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The Supreme Court held that when a member of the original panel of the court of appeals leaves the bench the departing judge may be replaced by a new judge on the panel that reconsiders its original decision.In this litigation centering around a soured business relationship between Plaintiff and Defendant the trial court issued a decision appointing a receiver to manage the dissolution of the business and ordering that the business be sold to Plaintiff. The court of appeals reversed and ordered the receiver to entertain offers from all interested bidders. After the case was argued but before the decision issued, Judge Horton announced his impending resignation, which became effective before Defendant filed his application for reconsideration. Judge Frederick Nelson was appointed to fill Judge Horton's seat. Defendant opposed reconsideration, arguing that Judge Nelson should not participate in the reconsideration decision because he did not sit on the original panel. The court of appeals disagreed and entered a new decision affirming the judgment of the trial court. The Supreme Court affirmed, holding that the court of appeals acted within the bounds of the law when Judge Nelson replaced Judge Horton on the panel considering Plaintiff's application for reconsideration. View "Jezerinac v. Dioun" on Justia Law

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In this case involving the proper scope of the litigation privilege in Ohio the Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court granting judgment on the pleadings concluding that certain actions of the Certified Steel Stud Association's directors were protected by the litigation privilege, holding that judgment on the pleadings was inappropriate.ClarkDietrich previously sued the Association alleging that the Association made defamatory statements about ClarkDietrich's products. William Gardner and Edward Slish (together, Appellees) were members of the Association's board of directors at that time. The jury returned a verdict in favor of ClarkDietrich. John Reister, who was subsequently appointed as a receiver on behalf of the Association, filed this action claiming that Appellees breached their fiduciary duties by mishandling the ClarkDietrich litigation. The court of appeals affirmed, concluding that Appellees' actions were protected under the litigation privilege rule. The Supreme Court reversed, holding (1) the litigation privilege protects statements, not actions; and (2) the decision to grant judgment on the pleadings was improper in this case. View "Reister v. Gardner" on Justia Law

Posted in: Business Law
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In this appeal concerning the trial court's award of $3,983,014 in attorney fees the Supreme Court reversed the judgment of the court of appeals affirming the award of attorney fees, holding that the "lodestar" reflected a reasonable fee based on the prevailing market rate for the services rendered by Appellees' attorneys, and therefore, the trial court's enhancement to the lodestar was in error.Appellees were awarded a jury verdict against Appellant for compensatory and punitive damages, treble damages, prejudgment interest, and litigation costs and expenses. In determining attorney fees, the trial court established a lodestar - the reasonable hourly rate multiplied by the number of hours worked - of $1,991,507. Then court then doubled the attorney fees due to the complexity and length of the case and the "highly favorable outcome" obtained by the attorneys. The court of appeals affirmed the award. The Supreme Court reversed, holding that Appellees' attorneys were reasonably compensated, so there should have been no enhancement to the lodestar. View "Phoenix Lighting Group, LLC v. Genlyte Thomas Group, LLC" on Justia Law

Posted in: Business Law
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The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of prohibition and dismissed as moot the motions Appellant filed in connection with the complaint, holding that the court of appeals correctly dismissed the complaint.In his complaint, Appellant sought to vacate charging orders and receivership orders concerning his membership interests in two limited liability companies, asserting that the orders exceeded the authority of Henry County Court of Common Pleas Judge John Collier. The court of appeals dismissed the complaint, concluding that Judge Collier did not patently and unambiguously lack jurisdiction to enter a charging order or to appoint a receiver. The Supreme Court affirmed, holding that because Judge Collier had subject matter jurisdiction to enter a charging order and to appoint a receiver, Appellant did not show that the judge patently and unambiguously lacked jurisdiction. View "State ex rel. Kerr v. Collier" on Justia Law

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In this quo warranto case in which the attorney general sought to dissolve Omar Ibn El Khattab Mosque, Inc. the Supreme Court granted Appellants' motion for reconsideration of the Court's decision affirming the decision of the court of appeals granting the writ, vacated its earlier decision, reversed the judgment of the court of appeals, and remanded the case with instructions to deny the writ, holding that this Court's initial decision was in error.The Ohio attorney general filed a complaint for a writ of quo warranto seeking to dissolve the corporation and appoint a receiver, alleging that the corporation violated three rules of corporate governance. The court of appeals issued a writ of quo warranto. The Supreme Court affirmed. The Court subsequently granted Appellants' motion for reconsideration and held that the writ should not issue. View "State ex rel. Yost v. Omar Ibn El Khattab Mosque, Inc." on Justia Law

Posted in: Business Law
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The Supreme Court affirmed the judgment of the court of appeals granting a writ of quo warranto sought by the attorney general and ordering the dissolution of Omar Ibn El Khattab Mosque, Inc., holding that the corporation’s failure to adhere to statutory requirements amounted to a surrender of the corporation’s rights and privileges necessitating the remedy of dissolution.Following its inception, the corporation failed to comply with corporate formalities, leading to internal disagreements. A rift subsequently formed between members of the corporation’s congregation, and competing boards of directors were elected, both claiming authority over the corporation and its charitable funds. The leadership struggle led to the funds being frozen and transferred to the Franklin County Clerk of Courts. The attorney general later brought this action seeking to dissolve the corporation. The court of appeals granted the writ and remanded the matter to the court of common pleas to supervise the winding down of the corporation and appoint a trustee or receiver to oversee the creation of a successor entity. The Supreme Court affirmed, holding that the facts established a causal link between the failure to observe corporate formalities and the congregation’s schism and the loss of charitable funds. View "State ex rel. DeWine v. Omar Ibn El Khattab Mosque, Inc." on Justia Law

Posted in: Business Law
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The Supreme Court granted a peremptory writ of prohibition to halt an action for an assignment for the benefit of a disbarred attorney’s creditors (the ABC action) pending before a Hamilton County probate judge. In 2004, nineteen judgment creditors filed a lawsuit alleging that the attorney at issue had stolen millions of dollars in settlement funds while representing them. A Kentucky trial court ruled that the attorney was jointly and severally liable for $42 million. The court of appeals affirmed. In 2013, the Kentucky Supreme Court permanently disbarred the attorney for his conduct in the underlying representation. In 2015, a Boone County circuit court judge ordered the attorney to transfer his beneficial interest in a company, which were held in trust for the purpose of winding up operations, to the creditors. The attorney did not transfer the shares to the creditors, and the shares were later transferred. The Supreme Court granted the creditors’ motion for a peremptory writ of prohibition barring further proceedings in the ABC action, holding that the necessary elements for a writ of prohibition to issue were all present in this case. View "State ex rel. McGirr v. Winkler" on Justia Law