AC Asset, L.L.C. v. Mitchell, 2022 Ohio 1763

AC Asset sued Chanel Mitchell and Taeylor Mitchell for forcible entry and detainer and unpaid rent for premises at 1383 W. 114th St.; complaint included the electronically executed lease and supporting documents.
Appellant (Chanel) denied signing or residing at the property, claimed identity theft, and submitted alternative leases, emails, a Wells Fargo payment report, and later a police report.
AC Asset introduced the Adobe Sign audit report, rental applications, photo/repair evidence, and testimony that both applicants electronically viewed and e-signed the lease (timestamps and IP-address data included).
The magistrate found AC Asset proved by a preponderance that Chanel signed the lease and awarded $2,287.85 after offsets; the housing court adopted the magistrate’s decision.
Chanel objected, raising for the first time the police report, text messages, and other supporting documents; the trial court declined to consider evidence she could have produced earlier and overruled objections.
On appeal Chanel argued (1) the electronic lease was defective for lack of notarization/witnessing, (2) she rebutted the presumption of a valid signature by showing identity theft, and (3) the court improperly relied on IP-address evidence without expert testimony. The court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity/enforceability of electronically signed lease	Adobe Sign audit, rental application, uploaded ID/paystub, audit timestamps and signatures establish authentic execution	Chanel denied signing, claimed Taeylor stole identity and forged her signature	Court held presumption of valid signature not rebutted; evidence supported magistrate's finding appellant signed lease
Challenge that lease was defective under Ohio Statute of Conveyances (not witnessed/notarized)	Lease valid and electronic signatures are legally effective	Chanel argued statute required witnessing/notarization for conveyances, rendering lease defective	Waived — issue not raised at trial or in timely objections; appellate court declined to consider it
Reliance on IP-address evidence without expert testimony	IP/address data and witness testimony showed appellant accessed and signed from employer-related IP; overall record supports finding	Chanel argued IP evidence required expert analysis and could not link signature to her without expert	Expert testimony not required: IP evidence was within common knowledge and corroborated by appellant’s own testimony; any error was harmless

Eastley v. Volkman, 972 N.E.2d 517 (Ohio 2012) (standard for reviewing weight of evidence and manifest-weight review)
State v. Thompkins, 678 N.E.2d 541 (Ohio 1997) (definition and use of manifest-weight standard)
Seasons Coal Co., Inc. v. Cleveland, 461 N.E.2d 1273 (Ohio 1984) (give trial court’s factual findings every reasonable presumption)
Ramage v. Cent. Ohio Emergency Servs., Inc., 592 N.E.2d 828 (Ohio 1992) (expert testimony required when issues are beyond common knowledge)
Darnell v. Eastman, 261 N.E.2d 114 (Ohio 1970) (expert testimony principles)
Forbes v. Midwest Air Charter, Inc., 711 N.E.2d 997 (Ohio 1999) (definition of rebuttable presumption)
Holliday v. Calanni Ents., 175 N.E.3d 663 (Ohio 2021) (burden of proof and preponderance of the evidence in civil cases)