Cty. Risk Sharing Auth., Inc. v. State
2022 Ohio 164
| Ohio Ct. App. | 2022Background
- CORSA sued the State, the Geauga Soil and Water Conservation District, the District Board, and an employee (Prunty) for a declaratory judgment that under R.C. 940.07 the State alone must defend and indemnify the District/Board/Prunty for an automobile accident while Prunty was employed by the District.
- The State counterclaimed that CORSA must defend and indemnify under CORSA’s Coverage Agreement (up to policy limits); the parties submitted joint stipulations saying the statute points to State responsibility while the Coverage Agreement points to CORSA responsibility subject to its terms.
- Discovery included a dispute over coverage‑agreement terms; the trial court denied the State’s motion to compel and set dispositive motion deadlines.
- Both sides filed timely motions for summary judgment; the State filed its reply to CORSA’s opposition on May 20, 2021 (within the 7‑day reply period), but the trial court granted CORSA’s motion earlier that same day (prematurely).
- The appellate court reversed and remanded, holding the trial court erred by ruling before the reply period expired and by issuing a conclusory Civ.R. 56 judgment entry lacking the required analysis; remaining merits assignments were not reached.
Issues
| Issue | Plaintiff's Argument (CORSA) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether the trial court erred by granting summary judgment before the movant’s reply period expired | Court could rule on the motions based on the record then before it | Premature ruling denied State the seven‑day reply under Civ.R. 6(C)/56 and violated due process | Reversed: ruling was premature; trial court must allow time for a timely reply before deciding |
| Whether the trial court fulfilled its Civ.R. 56(C) duty to consider all timely filings | The existing filings were sufficient for decision | Trial court failed to read/consider all materials (including the State’s reply) as required | Reversed: trial court must read and consider all appropriate materials before ruling |
| Whether the judgment entry provided sufficient analysis for appellate review | The entry adequately resolved the motions | The entry was conclusory and did not explain the court’s reasoning, forcing appellate substitution | Reversed: judgment entry lacked required reasoning; trial court must issue a meaningful Civ.R. 56 entry |
| Whether remaining appellate issues may be decided on this record | CORSA: merits support summary judgment in its favor | State: merits cannot be resolved until trial court follows proper procedure | Not reached: remanded for the trial court to consider all timely summary‑judgment materials and issue reasoned rulings |
Key Cases Cited
- Murphy v. Reynoldsburg, 65 Ohio St.3d 356 (1992) (trial court has an absolute duty to read and consider all materials before ruling on summary judgment)
- Hooten v. Safe Auto Ins. Co., 100 Ohio St.3d 8 (2003) (trial court must allow time for a movant’s reply before ruling; premature summary‑judgment rulings implicate due process)