2026-Ohio-678
Ohio Ct. App. 6th2026Background
- FTFT Supercomputing leased an industrial building from Benedict Firelands Platt under a commercial lease running from December 2023 to August 2028. 1
- Benedict sued FTFT for forcible entry and detainer, alleging FTFT defaulted, the lease was terminated, and FTFT remained in possession after notice to leave. 2
- FTFT failed to appear at the eviction hearing, and the municipal court entered judgment granting Benedict a writ of restitution on December 6, 2024. 3
- After that final judgment, FTFT filed an answer, counterclaims, and injunctive motions, then sought transfer to common pleas court based on counterclaims exceeding municipal court jurisdiction. 4
- The municipal court transferred the case, but the common pleas court struck FTFT's filings because they were filed after final judgment in the municipal court. 5
- FTFT later filed a Civ.R. 60(B) motion in municipal court, and that court struck it for lack of jurisdiction because the case had been transferred. 6
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did municipal court have jurisdiction over FTFT's Civ.R. 60(B) motion? 7 | Benedict said transfer and common-pleas proceedings divested municipal court jurisdiction. | FTFT said only municipal court could vacate its final judgment. | Municipal court had jurisdiction to consider the timely Civ.R. 60(B) motion. 8 |
| Was the postjudgment transfer effective after final judgment had already been entered? 9 | Benedict argued FTFT's transfer-based challenge was time-barred and invited error. | FTFT argued no case remained pending, so the transfer was a nullity. | The transfer had no effect because no case was pending when ordered. 10 |
| Could the common pleas court's dismissal strip municipal court power to hear relief from judgment? 11 | Benedict said the common pleas judgment controlled and precluded municipal-court relief. | FTFT said the common pleas court could not vacate the municipal court's judgment. | Only the municipal court could entertain relief from its own final judgment. 12 |
Key Cases Cited
- Servpro v. Kinney, 2010-Ohio-3494 (9th Dist.) (trial court loses jurisdiction after final judgment; postjudgment transfer after no pending case is ineffective 13)
- In re Criminal Charges Against Groves, 2018-Ohio-1406 (4th Dist.) (a court loses jurisdiction after final judgment absent civil-rule authority 14)
- Pitts v. Ohio Dept. of Transp., 67 Ohio St.2d 378 (Ohio 1981) (actions taken outside authorized postjudgment motions are void 15)
- Lingo v. State, 2014-Ohio-1052 (Ohio Ct. App.) (a void judgment may be challenged at any time 16)
- State v. Harroff, 1976 WL 191092 (8th Dist. 1976) (a motion to vacate must be filed in the rendering court 17)
- Perdrix Machinery Sales, Inc. v. Papp, 116 Ohio App. 291 (6th Dist. 1962) (only the rendering court may vacate its judgment 18)
- Pratts v. Hurley, 2004-Ohio-1980 (Ohio 2004) (distinguishes subject-matter jurisdiction from jurisdiction over a particular case 19)
- State ex rel. Schwarzmer v. Mazzone, 2025-Ohio-1246 (Ohio 2025) (improper exercise of jurisdiction over a particular case is voidable, not void 20)
- State ex rel. Dannaher v. Crawford, 1997-Ohio-72 (Ohio 1997) (a transfer-order challenge may be reviewed after final judgment 21)
- In re J.J., 2006-Ohio-5484 (Ohio 2006) (procedural transfer irregularities render a judgment voidable, not void 22)