Champlin v. Kraftmaid Cabinetry, Inc.
190 Ohio App. 3d 202
| Ohio Ct. App. | 2010Background
- Dec. 20, 1999, Kraftmaid employee DeVito collided with Champlins’ vehicle, causing severe injuries to Charlene and lesser injuries to Ronald.
- Charlene required life flight, underwent multiple injuries, and incurred about $30,000 in medical expenses; her dizziness prevented work.
- Plaintiffs filed suit Oct. 31, 2001; case submitted to private binding arbitration in May 2003, resulting in an award of $725,000 for plaintiffs.
- Trial court confirmed the arbitration award on May 6, 2004.
- Appellants appealed Champlin I challenging the court’s jurisdiction to confirm the award because payment had already occurred.
- While Champlin I was pending, appellees sought prejudgment interest under R.C. 1343.03(C); matter later returned to trial court for ruling on prejudgment interest.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court had jurisdiction to award prejudgment interest after arbitration | Champlin asserts trial court retains authority to award prejudgment interest | Appellants contend the arbitration panel exclusive jurisdiction barred trial court prejudgment interest | Trial court retained jurisdiction to award prejudgment interest despite arbitration |
| Whether the evidence supports a finding of good-faith effort to settle | Champlin showed consistent settlement efforts and reliance on experts | Kraftmaid claims defendants acted in bad faith and delayed settlement | Court properly found appellants failed to make a good-faith settlement effort; good-faith standard satisfied risk assessment factors |
| Effect of high/low arbitration agreement on prejudgment interest | Interest may be awarded beyond arbitration award within the ceiling | High/low limits prejudgment interest to ceiling; not allowed beyond | Interest awarded but limited to $25,000 to conform to high/low agreement |
| Whether prejudgment interest amount should be capped by the high/low ceiling | Interest should reflect full pendency and damages | Ceiling cap controls; no excess beyond ceiling | Affirmed interest award as modified to $25,000 in accordance with high/low term |
Key Cases Cited
- Miller v. Gunckle, 96 Ohio St.3d 359 (2002) (arbitration panel may award prejudgment interest under R.C. 1343.03(C))
- Kalain v. Smith, 25 Ohio St.3d 157 (1986) (four-factor test for good-faith settlement)
- Moskovitz v. Mt. Sinai Med. Ctr., 69 Ohio St.3d 638 (1994) (purpose of prejudgment interest; who bears burden)
- Pruszynski v. Reeves, 117 Ohio St.3d 92 (2008) (trial court must set a date certain for evidentiary prejudgment-interest hearing)
- Carden v. Miami Hardware & Appliance Co., Inc., 113 Ohio App.3d 220 (1996) (arbitral award and prejudgment interest procedure)
- Detelich v. Gecik, 90 Ohio App.3d 793 (1993) (good-faith settlement factors)
- Manning v. Advanced Technology Incubator, 2003-Ohio-2537 (2003) (trial court retains jurisdiction to determine prejudgment interest after confirming arbitration award)