Justia Ohio Supreme Court Opinion Summaries

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

The Supreme Court held that in order to compel arbitration against a union employee, the claim must have been clearly and unmistakably waived in arbitration provisions in the collective-bargaining agreement (CBA) governing the parties, and to be clear and unmistakeable the claim must be included either by statute or specific cause of action in the arbitration provisions of the CBA.Plaintiff brought this intentional employer tort action under Ohio Rev. Code 2745.01. The trial court denied Defendant's ensuing motion to stay the proceedings and to compel arbitration. The court of appeals affirmed, holding that because the parties' CBA made no mention of Ohio Rev. Code 2745.01 or intentional torts, Plaintiff had not waived his right to pursue such a claim in a judicial forum. The Supreme Court affirmed, holding that because Plaintiff's claim for an intentional tort was not mentioned in the CBA, Defendants did not clearly and unmistakably agree to prohibit resolution of the claim in court. View "Sinley v. Safety Controls Technology, Inc." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint seeking an order prohibiting the general division judge from exercising further authority over some of the claims in the underlying case, holding that the court of appeals properly dismissed the complaint.Appellant brought an action against the estate of his ex-wife in the general division of the court of common pleas seeking to recover funds to which Appellant claimed he was entitled under the former spouses' separation agreement. The state filed a counterclaim against Appellant. The trial court ruled (1) Appellant was entitled to $15,353, but there were genuine issues that precluded summary judgment on his remaining claims; and (2) the estate was entitled to partial summary judgment on its counterclaims. Appellant then filed a complaint for a writ of prohibition seeking to prevent the judge from taking further action on the estate's counterclaim. The court of appeals dismissed the complaint. The Supreme Court affirmed, holding that the general division did not patently or unambiguously lack subject-matter jurisdiction, and Appellant had an adequate legal remedy by way of direct appeal. View "State ex rel. Gray v. Kimbler" on Justia Law

The Supreme Court held that the delayed opening of an amusement park owned by Defendant caused by the government-mandated shutdown imposed by the state in response to the COVID-19 pandemic did not, by itself, establish a claim by a season-pass holder that Defendant breached the terms and conditions of the season pass it issued for the 2020 season.Plaintiff, a season-pass holder, brought this action asserting breach of contract and unjust enrichment for Defendant's failure to open its amusement parks in May and June 2020. The trial court dismissed the complaint with prejudice. The court of appeals reversed, finding that the parties were subject to the terms and conditions of the pass and that Defendant could not revoke the season pass without compensating Plaintiff. The Supreme Court reversed, holding (1) according to the terms and conditions tissue, Defendant could change its dates of operation without advance notice and close attractions for the government-mandated shutdown; and (2) therefore, Plaintiff's breach of contract action failed as a matter of law, and there was no unjust enrichment. View "Valentine v. Cedar Fair, L.P." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the summary judgment entered by the Cuyahoga County Court of Common Pleas in favor of Warrensville Heights in this real property dispute, holding that the agreement between the parties in this case was valid and enforceable.The Beachwood City School District Board of Education sought approval from the state board of education for a transfer of territory it annexed in 1990 to the Beachwood City School District. The Warrensville Heights City School District Board of Education, whose district the annexed territory was a part of, objected. In 1997, Beachwood and Warrensville Heights agreed that the territory would not transfer to the Beachwood City School District but that the districts would share the tax revenue generated from real property located within the territory. The court of common pleas granted summary judgment for Warrensville Heights, concluding that the parties' agreement was not valid. The court of appeal reversed. The Supreme Court affirmed, holding that the 1997 agreement required neither approval nor a fiscal certificate and therefore was valid and enforceable. View "Beachwood City School District Bd. of Education v. Warrensville Heights City School District Bd. of Education" on Justia Law

The Supreme Court held that an action seeking a determination that an oil and gas lease has expired by its own terms is a controversy "involving the title to or the possession of real estate" so that the action is exempt from arbitration under Ohio Rev. Code 2711.01(B)(1).Appellants brought an action for declaratory judgment alleging that oil and gas leases between the parties had terminated because Appellee failed to produce oil or gas or to commence drilling operations within the terms of the lease. Appellee moved to stay pending arbitration. The trial court denied the request, concluding that Appellants' claims involved the title to or the possession of real property, and therefore, were exempt from arbitration under Ohio Rev. Code 2711.01(B)(1). The court of appeals reversed. The Supreme Court reversed, holding the trial court correctly declined to stay the action in this case pending arbitration. View "French v. Ascent Resources-Utica, LLC" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the trial court ruling that an umbrella insurance policy between Motorists Mutual Insurance Company (Motorists)and Owens-Brockway Glass container, Inc. (Owens) did not apply to claims made against Ironics, Inc. by Owens, holding that the court of appeals did not err.Owens asserted claims against Ironics for, among other claims, breach of contract. Ironics asked its insurer, Motorists, to defend and indemnify it against Owens's claims under a commercial general-liability policy and a commercial umbrella policy with Motorists. The trial court concluded that neither policy covered Owens's claims and granted summary judgment for Motorists. The court of appeals reversed in part, holding that Ironics was entitled to coverage under the umbrella policy. The Supreme Court affirmed, holding that Owens's claims arose out of an accident that resulted in "property damage" under Ironic's umbrella policy with Motorists and that none of the policy's exclusions applied. View "Motorists Mutual Insurance Co. v. Ironics, Inc." on Justia Law

The Supreme Court held that a provision found in just about every commercial and personal-property insurance policy issued in Ohio that bars coverage for damage caused by "water that backs up or overflows from a sewer" includes damage caused by sewage carried into an insured property by a backup or overflow event.Sewage from the local sewer system backed up into the Bank Nightclub, a bar that was insured at the time by United Specialty Insurance Company. The bar subsequently hired Cleantech to clean up the site and submitted a claim to its insurer. United Specialty denied the claim, citing an exclusion in the bar's policy for damage caused by water that backs up or overflows from a sewer. The bar assigned AKC any claims it might have against United Specialty, and AKC then brought this breach of contract claim. The trial court granted summary judgment in favor of United Specialty. The court of appeals reversed. The Supreme Court reversed, holding that the water-backup exclusion in the policy included damage caused by the sewage. View "AKC, Inc. v. United Specialty Insurance Co." on Justia Law

In this breach of contract action, the Supreme Court reversed the judgment of the court of appeals applying the common-law requirements set out in Globe Indemnity Co. v. Schmitt, 53 N.E.2d 790 (Ohio 1944), without considering whether the parties intended to abrogate those requirements, holding that the Globe Indemnity Co. requirements do not apply when the parties express a clear intent to abrogate those common-law requirements in their contract.On appeal, Appellant argued that the common-law requirements set out in Globe Indemnity Co. for determining whether an indemnitee may recover against an indemnitor when the indemnitee has settled a claim without the indemnitor's involvement do not apply when the parties express a clear intent to abrogate those requirements in their contract. The Supreme Court agreed and reversed the court of appeals' judgment, holding (1) the requirements set forth in Globe Indemnity Co. do not apply when the parties express a clear intent to abrogate those common-law requirements in their contract; and (2) the lower courts erred by failing ascertain whether the parties intended to abrogate the common-law requirements for indemnification. View "Total Quality Logistics, LLC v. JK & R Express, LLC" on Justia Law

The Supreme Court held that the common-law requirements set out in Globe Indemnity Co. v. Schmitt, 53 N.E.2d 790 (Ohio 1944), for determining whether and indemnitee may recover against an indemnitor when the indemnitee has settled a claim without the indemnitor's involvement, do not apply when the parties express a clear intent to abrogate those common-law requirements.The court of appeals in this breach of contract action concluded that the Globe Indemnity Co. requirements apply regardless of the terms of the parties' contract. The Supreme Court reversed, holding that the court of appeals erred by applying the common-law requirements set out in Globe Indemnity Co. without considering whether the parties abrogated those requirements in their contract. The Court remanded this matter to the trial court for further proceedings. View "Wildcat Drilling, LLC v. Discovery Oil & Gas, LLC" on Justia Law