Healey v. Goodyear Tire & Rubber Co.
2012 Ohio 2170
Ohio Ct. App.2012Background
- Healey, a former Goodyear employee, sued Goodyear and supervisor for post-employment retaliation after she complained of gender discrimination.
- The trial court granted Goodyear and Medkeff summary judgment; this court affirmed for lack of admissible non-hearsay evidence and no causal link.
- Healey later sought relief under Civ.R. 60(B)(2) based on newly discovered evidence (Wenger affidavit) alleging Medkeff made a negative reference.
- The trial court held Civ.R. 60(B)(2) relief inappropriate and that the evidence did not establish a causal connection.
- On appeal, the court discussed whether Civ.R. 60(B)(2) applies to summary judgment and whether the new evidence could change the outcome, ultimately affirming the judgment.
- The court declined to address the related assignments of error as moot and reaffirmed that Healey failed to establish a prima facie case of retaliation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Civ.R. 60(B)(2) applicability to summary judgment | Healey argues 60(B)(2) can relief after summary judgment | Goodyear contends 60(B)(2) does not apply in this context | Motion not meritorious; 60(B)(2) not justify relief despite new evidence |
| Causation under retaliation framework | New evidence may show causal link between protected activity and retaliation | Temporal gap (12–24 months) negates causal inference absent other evidence | No prima facie retaliation shown; causal link not established |
| Law of the case and prior decision | Healey challenged law-of-the-case implications on causation | Court's prior holding remains controlling for causation analysis | moot after dispositive ruling on 60(B)(2) issue |
Key Cases Cited
- Holden v. Ohio Bur. of Motor Vehicles, 67 Ohio App.3d 531 (9th Dist.1990) (newly discovered evidence requires actual novelty, diligence, materiality)
- Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (abuse of discretion standard and review framework)
- Pons v. Ohio State Med. Bd., 66 Ohio St.3d 619 (1993) (abuse of discretion; standard for reviewing Civ.R. 60(B) decisions)
- Griffey v. Rajan, 33 Ohio St.3d 75 (1987) (trial court discretion in 60(B) rulings; standard of review)
- First Fin. Servs., Inc. v. Cross Tabernacle Deliverance Church, Inc., 2007-Ohio-4274 (10th Dist.) (Civ.R. 60(B) analysis in related setting; 60(B) motion context)