Justia Ohio Supreme Court Opinion Summaries

Scott and Dawn Smith (together, Insureds) filed an insurance claim with Erie Insurance Company (Insurer) seeking uninsured-motorist coverage as a result of injuries suffered by Scott in a no-contact accident allegedly caused by an unidentified vehicle. Insurer denied the claim. The trial court granted summary judgment to Insurer, concluding that a provision in the policy requiring Insureds to provide “independent corroborative evidence” that the unknown driver caused the injury meant that Insureds had to submit evidence, independent of Scott’s own testimony, corroborating that the accident was caused by an unknown motorist, and this they failed to do. The court of appeals reversed. The Supreme Court affirmed, holding that the policy’s requirement of independent corroborative evidence could be met using evidence derived from the insured’s testimony. View "Smith v. Erie Insurance Co." on Justia Law

Respondents, landowner-lessors, filed a putative class action in federal court claiming that Petitioner, the lessee, underpaid gas royalties under the terms of their leases. Under each lease, the lessee must bear all the production costs. The federal court certified to the Ohio Supreme Court a question regarding whether the lessee was permitted to deduct postproduction costs from the lessors’ royalties and, if so, how those costs were to be calculated. Specifically, the federal court asked the Supreme Court whether Ohio follows the “at the well” rule, which permits the deduction of post-production costs, or whether it follows some version of the “marketable product” rule, which limits the deduction of post-production costs under certain circumstances. The Supreme Court declined to answer the certified question and dismissed the cause, holding (1) under Ohio law, an oil and gas lease is a contract that is subject to the traditional rules of contract construction; and (2) therefore, the rights and remedies of the parties in this case are controlled by the specific language of their lease agreement. View "Lutz v. Chesapeake Appalachia, L.L.C." on Justia Law

The Village of Piketon and Boone Coleman Construction, Inc. entered into a contract for construction of a public road. The contract contained a liquidated damages provision specifying that Boone Coleman would pay $700 to Piketon for each day after the specified completion date that the contract was not substantially completed. Boone Coleman did not complete the project until well over a year after the parties’ extended completion date. Boone Coleman sued Piketon alleging that Piketon had failed to pay $147,477 of the contract price for the construction. Piketon filed a counterclaim seeking liquidated damages. The trial court awarded Piketon $277,900 in liquidated damages. The appellate court reversed, holding that the resulting amount of liquidated damages was so unreasonable as to constitute a penalty. The Supreme Court vacated the judgment of the court of appeals, holding that the court erred in its use of a retrospective analysis to reach its conclusion and in failing to focus on the per diem nature of the liquidated damages. Remanded for consideration of the enforceability of the liquidated damages provision in light of this opinion. View "Piketon v. Boone Coleman Constr., Inc." on Justia Law

These consolidated actions involved an original action in the Supreme Court and an appeal of a judgment of the court of appeals and concerned the interpretation of several nearly identical oil and gas leases. In the original action, Relator, an absent and unnamed plaintiff in a class action, challenged the court of appeals’ order tolling the leases in the class action pending appeal and sought writs of prohibition and mandamus. The appeal challenged the court of appeals’ interpretation of the leases in the class action. The Supreme Court (1) affirmed the judgment of the court of appeals in the class action, holding that the court of appeals correctly interpreted the leases; (2) denied a writ of mandamus or prohibition in the original action because Relator had an adequate remedy in the ordinary course of law by moving to intervene in the appeal and because the court of appeals did not patently and unambiguously lack jurisdiction to issue an order tolling the leases; and (3) denied the motions of the appellee in the appeal to toll the terms of the leases. View "State ex rel. Claugus Family Farm, L.P. v. Seventh Dist. Court of Appeals" on Justia Law

A landowner filed a complaint for breach of contract against the predecessor in interest to Huntington National Bank. The trial judge ruled in favor of the landowner and awarded damages. The court of appeals reversed on the issue of the proper standard for calculating damages and remanded the case for a recalculation. On remand, the trial judge ordered a new evidentiary hearing on damages, concluding that the court could not arrive at a proper measure of damages without additional testimony. Huntington filed this action in procedendo and prohibition in the court of appeals and filed a notice of appeal of the trial court’s order. The court of appeals (1) dismissed the appeal on grounds that the order requiring a new hearing was not a final appealable order, and (2) dismissed the procedendo and prohibition petition, concluding that Huntington had an adequate remedy by way of appeal and that the trial court did not exceed its jurisdiction by ordering an evidentiary hearing. The Supreme Court affirmed, holding that Huntington had an adequate remedy at law by way of appeal and that the trial judge’s jurisdiction to order the evidentiary hearing and to determine damages based on new evidence was not patently and ambiguously lacking. View "State ex rel. Huntington Nat'l Bank v. Kontos" on Justia Law

Pilkington North America, Inc. entered into a social contract with Toledo Edison Company under which Toledo provided one of Pilkington’s facilities with discounted electric service. The Public Utilities Commission approved the special contract. Pilkington later filed a complaint alleging that Toledo Edison had unlawfully terminated the special contract. Five other companies that also had special contracts with the utility also filed complaints against Toledo Edison. The Commission consolidated the six complaints and dismissed them. With the exception of Pilkington, each of the industrial customers appealed the Commission’s decision. The Supreme Court reversed the Commission’s order, concluding that Toledo Edison had prematurely terminated the special contracts. Pilkington subsequently filed a Ohio R. Civ. P. 60(B) motion for relief from judgment with the Commission seeking relief from the Commission’s order dismissing its complaint and its order denying the application for rehearing that the other five complainants filed. The Commission denied Pilkington’s motion, concluding that Pilkington may not use Rule 60(B) as a substitute for appeal. The Supreme Court affirmed, holding that because Pilkington did not appeal the Commission’s adverse judgment, that judgment is final, and res judicata precludes the use of Rule 60(B) to obtain relief from that final judgment. View "In re Complaint of Pilkington N. Am., Inc." on Justia Law

This contract dispute was a portion of ongoing litigation initiated by the governing Boards of ten Cleveland community schools (“the schools”). Defendants were two private for-profit companies and ten subsidiary companies that operated and managed the schools (collectively, “White Hat”) pursuant to contracts with each school. The State Board of Education was also named in the complaint. The governing authorities of the schools filed suit challenging the operation of a buy-back provision of the contracts stating that the schools could retain personal property owned and used by White Hat in the schools’ daily operations after termination of the contracts only by paying certain payments to the management companies. The court of appeals affirmed the trial court’s judgment in favor of White Hat. The Supreme Court affirmed the judgment of the court of appeals to the extent that it held that the buy-back provision of the contracts was enforceable and that the schools were obligated under that provision to pay for the personal property purchased by White Hat as described in the contract. Remanded to the trial court for an inventory of the property at issue and its disposition according to the contracts. View "Hope Academy Broadway Campus v. White Hat Mgmt., LLC" on Justia Law

Insurer issued an automobile policy to Philip Laboy as the named insured. The policy provided that Insurer would pay “any negotiated reduced rate accepted by a medical provider.” Three members of Laboy’s family, also insureds under the policy, were involved in an automobile accident. The Laboys submitted some of their medical bills both to Insurer and to their health-insurance provider. The Laboys later reached a settlement with the third-party tortfeasor. When Insurer exercised its contractual right to subrogation against the Laboys, the Laboys objected, arguing that Insurer had overpaid the medical providers. As evidence, the Laboys showed that Insurer had paid discounted rates to medical providers totaling $1,441 in medical expenses but that their own health insurer paid only $648 for those same medical expenses. The Laboys filed a class-action lawsuit against Insurer, alleging claims for breach of contract and breach of good faith and fair dealing. The trial court entered summary judgment for Insurer. The Supreme Court agreed with the trial court’s judgment, holding that the only reasonable interpretation of the policy is that “any negotiated reduced rate accepted by a medical provider” means a negotiated reduced rate that Insurer was contractually entitled to pay and does not include the reduced rates negotiated by the Laboys’ health-insurance provider. View "Laboy v. Grange Indem. Ins. Co." on Justia Law

This case stemmed from alleged acts of pre-leasing housing discrimination that resulted in alleged emotional distress. At the relevant time, the defendants in the underlying case (“Insureds”) were covered under an umbrella insurance policy issued by Insurer. After Insureds settled the underlying case, Insureds sued Insurer for breach of contract for failing to defend Insureds pursuant to the umbrella policy. A federal trial court granted summary judgment in favor of Insurer on its duty to defend and indemnify Insureds under the umbrella policy. The federal court of appeals reversed. At issue before the Supreme Court was whether the umbrella policy’s intentional-acts exclusion - through application of the inferred-intent doctrine - obviated Insurer’s duty to defend in this case. The Supreme Court affirmed, holding (1) the umbrella policy at issue here arguably provides coverage for emotional-distress damages through its coverage for humiliation; and (2) emotional-distress damages are not inherent in a claim for discrimination, and therefore, the inferred-intent doctrine was inapplicable. View "Granger v. Auto-Owners Ins." on Justia Law

Kohl’s Illinois, Inc. filed a valuation complaint challenging the tax year 2010 valuation of a Kohl’s store in Marion County. The Board of Revision (BOR) dismissed the case, finding that the complaint was void because the property was subject to a tax-increment-financing (TIF) agreement that contained a covenant prohibiting the filing of a complaint against the value. The Board of Tax Appeals (BTA) affirmed the decision of the BOR. The Supreme Court vacated the decision of the BTA, holding (1) any bar to the complaint that arises from the TIF agreement is not a jurisdictional restriction, and therefore, the complaint was not void; (2) the beneficiaries of the covenant had the burden to assert the covenant as a defense against Kohl’s complaint; and (3) because the beneficiaries did not shoulder the burden to prove their entitlement to a dismissal of Kohl’s complaint, the decision of the BTA must be vacated. Remanded. View "Kohl’s Ill., Inc. v. Bd. of Revision" on Justia Law