Baltimore v. Ansel, 2017 Ohio 7347

Village of Baltimore (through RITA) filed a small‑claims complaint against Sarah K. Ansel seeking $629.22 for unpaid municipal income taxes (2010–2015). Complaint included employee affidavit and auditor statement of account.
Summons/notice set trial for Feb. 28, 2017 at the Fairfield County Municipal Court; Ansel was served by certified mail.
At the Feb. 28 proceeding the court entered judgment for plaintiff for $629.22 plus 4% interest and costs; the court’s entry states plaintiff’s representative (Gabe Lancione) appeared and the defendant “failed to appear,” but the entry also notes evidence and sworn testimony were considered.
Ansel appealed, claiming she was present at the courthouse but missed her case being called (due process), the court refused to recall the case after her presence was made known, and that Lancione (a non‑lawyer RITA employee) improperly prosecuted the case.
On appeal the court observed no trial transcript or statement of proceedings was filed by Ansel; under Knapp, omissions in the record require the reviewing court to presume regularity of the lower court’s proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether default judgment/entry against Ansel violated due process because she was present but did not hear her case called	RITA: trial properly noticed and proceeded; judgment supported by evidence	Ansel: she was at courthouse but missed call and was deprived of fair trial	Overruled — appellate court affirmed because no transcript was provided; under Knapp regularity of proceedings is presumed
Whether summons was defective for failing to show a courtroom number	RITA: notice substantially complied with R.C. 1925.05 by giving court address, date, and time	Ansel: summons insufficient for lack of courtroom number	Overruled — court found notice complied with statute and no showing that room number was necessary
Whether RITA’s non‑lawyer employee (Lancione) improperly prosecuted case (unauthorized practice of law)	RITA: authorized non‑lawyer employee may commence and prosecute small‑claims tax actions under statutory scheme	Ansel: Lancione cross‑examined/argued and thus engaged in unauthorized practice	Overruled — issue waived for failure to raise below; and without transcript court couldn’t determine advocacy; statutory authority permits non‑lawyer appearance by political subdivision employee

Knapp v. Edwards Laboratories, 61 Ohio St.2d 197 (establishes presumption of regularity where appellant fails to provide necessary transcript)
Cleveland Bar Assn. v. Pearlman, 106 Ohio St.3d 136 (discusses limits on layperson advocacy in small claims; lay officer may appear for entity provided they do not engage in advocacy such as cross‑examination or legal argument)