Justia Ohio Supreme Court Opinion Summaries

The Supreme Court denied the writ of mandamus sought by Alex Penland, an inmate at the Toledo Correctional Institution (TCI), to compel Respondents to make available for inspection the contract under which a vendor was permitted to sell food to inmates confined in Ohio prisons, holding that Penland failed to establish that he was entitled to the writ.Penland brought his complaint against Respondents, the Ohio Department of Rehabilitation and Correction and Sonrisa Sehlmeyer, alleging that he made a public-records request to Sehlmeyer asking to review the contract but did not immediately receive a response to his request. When the subsequent inmate grievance process brought by Penland was not resolved to his satisfaction Penland filed this original action. The Supreme Court denied the writ, holding that Penland did not show that Respondents had a clear legal duty to deliver the contract to TCI for Penland's inspection at no cost to him. The Court further denied Penland's request for statutory damages because Penland did not deliver his request to Sehlmeyer by hand or by certified mail. View "State ex rel. Penland v. Ohio Department of Rehabilitation & Correction" on Justia Law

The Supreme Court reversed the decision of the court of appeals holding that Ohio Rev. Code 1308.16(A) allows a purchaser of a bond to assert a breach-of-contract claim that accrued before the bondholder's purchase because the purchaser acquired the rights of one who held the bond when the breach allegedly occurred, holding that absent a valid assignment of a right to bring a cause of action, the sale of a municipal bond does not automatically vest in the purchaser.This breach-of-contract case came to the Supreme Court on appeal from a judgment finding that the court of common pleas erred by refusing to certify a class action on grounds that the class lacked commonality. Plaintiff asked the trial court to certify a class of bondholders. The trial court concluded that commonality had not been established because each class member would allege a different time and purchase price as the basis for a breach and thus would have different potential damages. The court of appeals reversed. The Supreme Court reversed, holding that absent a valid assignment of claims, the sale of a municipal bond does not automatically vest in the buyer all claims and causes of action of the seller relating to the bond that arose before the transaction. View "Paul Cheatham I.R.A. v. Huntington National Bank" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the trial court's judgment granting Plaintiff's motion to certify a class action, holding that when a class-certification case originates with a single named plaintiff and that plaintiff is not subject to an arbitration agreement that was entered into by unnamed putative class members, the defendant need not raise a specific argument referring or relating to arbitration in the defendant's answer.Plaintiff filed a class-action complaint against Defendant, his former employer. When Plaintiff moved to certify the case as a class action Defendant opposed the motion, asserting the defense of arbitration. The trial court granted the motion, concluding that Defendant waived any right of arbitration. The appellate court affirmed, determining that Defendant's failure to assert the arbitration defense in his answer or to seek to enforce the right to arbitration prior to its opposition to the certification was inconsistent with its right to assert the defense. The Supreme Court reversed, holding (1) because arbitration was not available as a defense at the time Defendant submitted its answer, Defendant could not waive a right to assert arbitration at that time; and (2) Defendant had no duty to raise an argument that Plaintiff failed to satisfy Civ.R. 23(A)'s typicality and adequacy requirements. View "Gembarski v. PartsSource, Inc." on Justia Law

The Supreme Court reversed the judgments of the court of appeals in this construction dispute, holding that Ohio's construction statute of repose, Ohio Rev. Code 2305.131, applies to any cause of action, whether sounding in contract or tort, so long as the cause of action meets the requirements of the statute.Plaintiff filed this action against several defendants, companies involved in the design and construction of a public school building, alleging claims for breach of contract. Defendants argued that the statute of repose on section 2305.131 barred Plaintiff's claims because substantial completion of the project occurred more than ten years before the claims were filed. The trial court agreed and dismissed the claims as time barred. The court of appeals reversed, concluding that section 2305.131 does not apply to breach of contract claims. The Supreme Court reversed, holding that section 2305.131 applies to both contract and tort claims. View "New Riegel Local School District Board of Education v. Buehrer Group Architecture & Engineering, Inc." on Justia Law

The Supreme Court answered two state-law questions from the Bankruptcy Appellate Panel for the United States Sixth Circuit Court of Appeals by holding that the failure to identify a person who has initialed, signed, and acknowledged a mortgage agreement by name in the body of the agreement does not render the agreement unenforceable as a matter of law against that signatory.The panel specifically asked whether a mortgage is invalid and unenforceable against a signatory who is not identified by name in the body of the mortgage agreement. The Supreme Court answered in the negative, holding that, as a matter of general contract interpretation, it is possible for a person who is not identified in the body of the mortgage, but who has signed and initiated the mortgage, to be a mortgagor of her interest. View "Bank of New York Mellon v. Rhiel" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant’s complaint for writs of mandamus and prohibition against Richland County Court of Common Pleas Judge James DeWeese seeking to compel Judge DeWeese to enter a final, appealable order on prior rulings made by Judge James Henson, vacate several orders Judge DeWeese had entered in the underlying case, and bar Judge DeWeese from moving forward with a trial, holding that Appellant was not entitled to the relief it sought.Appellant filed a complaint for breach of contract. Judge Henson granted summary judgment in favor of Appellant as to certain defendants. The trial court then awarded Appellant attorney fees. While appeals that were ultimately dismissed for lack of a final, appealable order were pending Judge Henson retired, and the case was reassigned to Judge DeWeese. Judge DeWeese vacated the summary judgment orders and granted summary judgment for one defendant. Appellant then filed this action. The court of appeals denied relief, and the Supreme Court affirmed, holding (1) Judge DeWeese clearly exercised jurisdiction in the underlying case, and that exercise of jurisdiction was authorized; and (2) because Appellant could not show that it had clear legal right to relief, it was not entitled to a writ of mandamus. View "State ex rel. Technical Construction Specialties, Inc. v. DeWeese" on Justia Law

At issue in this case was when Appellees’ claims for negligence, constructive fraud, and fraudulent concealment accrued and whether they were time-barred.Appellees were the Estate of Steven Schmitz and Yvette Smith, individually and as fiduciary of the Estate. Steven died before age sixty after being diagnosed with chronic traumatic encephalopathy, a degenerative brain disease, and dementia. Appellees alleged that Steven’s diagnoses were caused, aggravated, and/or magnified by repetitive head impacts Steven sustained while playing football for the University of Notre Dame du Lac. The trial court dismissed the claims pursuant to Ohio R. Civ. P. 12(B)(6). The Supreme Court affirmed the Eighth District’s judgment reversing the dismissal of Appellees’ claims for negligence, constructive fraud, and fraudulent concealment, holding (1) Rule 12(B)(6) did not warrant the dismissal of Appellees’ claims because the amended complaint did not show conclusively that the claims were time-barred; and (2) Appellees’ fraud-related claims were subject to the same two-year statute of limitations contained in Ohio Rev. Coe 2305.10(A) as Appellees’ negligence claim. View "Schmitz v. National Collegiate Athletic Ass’n" on Justia Law

In this case alleging breach of contract, fraud, retaliation, constructive discharge, and invasion of privacy, the Supreme Court held (1) in Ohio, punitive damages may not be awarded for a breach of contract; (2) a party to a contract does not breach the implied duty of good faith and fair dealing by seeking to enforce the agreement as written or by acting in accordance with its express terms, and the implied duty is not breached unless a specific obligation imposed by the contract is not met; (3) a release of liability is an absolute bar to a later action on any claim encompassed within it absent a showing of fraud, duress, or other wrongful conduct in procuring it, and a party must prove duress by clear and convincing evidence; (4) the prevention of performance doctrine is not a defense to a release of liability and therefore cannot be asserted as a defense to a release; and (5) a claimant cannot rely on predictions or projections that relate to future performance or that are made to third parties to establish a fraud claim. View "Lucarell v. Nationwide Mutual Insurance Co." on Justia Law

At issue was a lessor’s right to terminate an oil and gas lease when a lessee fails to make minimum annual rental or royalty payments. The trial court granted summary judgment in favor of the lessors in this case and ordered forfeiture of the lease at issue, declaring that the lease had terminated under its own terms because the lessees had failed to a minimum annual rental of $5,500 under the lease and that the lease was void as against public policy. The court of appeals reversed. The Supreme Court affirmed, holding (1) the provision in the lease requiring the lessee to pay $5,500 annually did not invoke the termination provision in the unrelated delay-rental clause; and (2) the lease did not qualify as a no-term, perpetual lease, and therefore, the lease was not void as against public policy. View "Bohlen v. Anadarko E&P Onshore, LLC" on Justia Law

Appellants and Grady Reed were shareholders in a closely held corporation. In a 2010 complaint, Reed alleged that Appellants had breached the shareholders’ agreement and demanded relief in the form of money damages. After a jury trial, Judge Richard Ferenc granted Reed’s motion for a directed verdict and awarded him money damages, apportioning the liability among Appellants in proportion to their shares in the corporation. The court of appeals reversed, concluding that the trial court erred by treating the complaint as an action for money damages when the only available remedy was specific performance. On remand, Judge Ferenc concluded that Appellants had no right to a jury trial because Reed’s predominant claim for relief was equitable in nature. Appellants sought a writ of prohibition arguing that Judge Ferenc’s exercise of judicial power was unauthorized by law and that they did not have an adequate remedy by way of appeal from his adverse rulings. The court of appeals granted Judge Ferenc’s motion to dismiss the complaint. The Supreme Court affirmed, holding that Appellants failed to establish their entitlement to a writ of prohibition. View "State ex rel. Samarghandi v. Ferenc" on Justia Law