Frank Novak & Sons, Inc. v. A-Team, L.L.C., 2014 Ohio 1730

Novak & Sons, Inc. obtained a judgment against A-Team, L.L.C. for $37,158.82 plus costs in a Cuyahoga County Court of Common Pleas action.
The certified judgment was transferred to Berea Municipal Court for collection on May 13, 2013.
An exemption hearing was held in Berea, and the magistrate found no exemptions for A-Team and directed levy.
A-Team moved to dismiss the Berea case and stay the magistrate’s finding; the trial court denied the motion.
A-Team appealed, arguing Berea Municipal Court lacked subject matter jurisdiction to proceed with collection.
The Eighth District reversed, holding Berea Municipal Court lacked jurisdiction to enforce the transferred judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Berea Municipal Court had jurisdiction to enforce a certified judgment over $15,000	Novak contends transfer allows enforcement within municipal jurisdiction.	A-Team argues the $15,000 limit strips municipal jurisdiction over execution.	Berea lacked subject matter jurisdiction.
Whether R.C. 1901.17 governs municipal jurisdiction over transferred judgments when amount exceeds limit	Novak relies on statutory framework permitting enforcement of transferred judgments under 1901.17/2329.02.	A-Team argues 1901.17 is a limiting provision governing municipal jurisdiction over such executions.	1901.17 is controlling; it limits municipal jurisdiction, so execution over $15,000 is improper.

Bowling v. Stafford & Stafford Co., L.P.A., 2008-Ohio-3768 (1st Dist. Hamilton) (municipal court may enforce transferred judgments only within its monetary jurisdiction)
Aselage v. Lithoprint Ltd., 2009-Ohio-7036 (2d Dist. Montgomery) (R.C. 2329.02 is general; R.C. 1901.17 is specific to municipal courts; the specific prevails)
Transamerica Commercial Fin. Corp. v. Mid-America Marine, Inc., 1993 Ohio App. LEXIS 3583 (11th Dist. Ashtabula) (R.C. 2390.02 confers limited aid in execution for judgments not exceeding municipal jurisdiction)