Hoffman v. Arthur
2021 Ohio 2318
| Ohio Ct. App. | 2021Background
- Probate Court granted summary judgment on Oct. 5, 2017, ordering Douglas Hoffman to repay $408,162.69; a judgment lien (2017JLD139) was issued Nov. 20, 2017.
- Parties (Hoffman, Guardian, Arthur, Jahweh LLC) executed a January 20, 2018 Settlement Agreement; the Probate Court’s Jan. 18, 2018 entry memorialized it and expressly retained jurisdiction to "implement, interpret or enforce" the Agreement and stated the sole venue for related litigation was the Coshocton County Common Pleas Court, Probate Division.
- Sandra Hoffman died in 2018; disputes over the judgment satisfaction and estate administration continued; Douglas moved for summary judgment in Probate (Oct. 22, 2019) seeking a finding the $408k judgment was satisfied; Probate denied that motion on Dec. 2, 2019.
- One day after the Probate denial, Douglas filed the same claims in Common Pleas (Dec. 3, 2019). Common Pleas granted Douglas summary judgment on June 25, 2020, ordering Arthur to file releases and declaring the lien satisfied; Arthur appealed and moved to vacate for lack of subject-matter jurisdiction.
- The appellate court held the jurisdictional-priority rule and the parties’ settlement/agreement (plus the Probate court’s retained jurisdiction order) deprived the Common Pleas Court of subject-matter jurisdiction over Hoffman’s claims; it reversed and remanded and denied Hoffman’s motion to dismiss the appeals for lack of a supersedeas bond.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Common Pleas had subject-matter jurisdiction to adjudicate satisfaction of the Probate judgment and order lien release | Hoffman sought declaratory and specific-performance relief in Common Pleas that the $408k Probate judgment was satisfied and the lien released | Arthur argued Probate retained exclusive jurisdiction (by agreement and Jan. 18, 2018 order) and the jurisdictional-priority rule barred Common Pleas | Common Pleas lacked subject-matter jurisdiction; Probate retained priority and exclusive jurisdiction over related matters; judgment reversed |
| Applicability of the jurisdictional-priority rule when parallel proceedings involve same parties and issues | Hoffman proceeded in Common Pleas after Probate denial and argued relief was proper in Common Pleas | Arthur argued Probate proceedings were first invoked and continuing, so later-invoked court must defer | Two-part test met; Probate’s prior invocation and retained jurisdiction meant the later Common Pleas action should be dismissed; Common Pleas erred in deciding the merits |
| Properness of summary judgment in Common Pleas on satisfaction of the Probate judgment | Hoffman contended there was no genuine issue of material fact and submitted settlement, Probate entries, deeds, and affidavits | Arthur contended factual and jurisdictional issues existed and that the matter belonged in Probate | Summary judgment was improper because subject-matter jurisdiction was lacking (disposition on jurisdictional grounds); appeals sustained |
| Motion to dismiss appeals for failure to post supersedeas bond | Hoffman sought dismissal because Arthur did not timely post bond per trial-court stay order | Arthur did not post bond pending appeal | Appellate court denied the motion to dismiss because it reversed on jurisdictional grounds; dismissal not well taken |
Key Cases Cited
- Dresher v. Burt, 75 Ohio St.3d 280 (movant's burden to show absence of genuine issue for summary judgment)
- Mitseff v. Wheeler, 38 Ohio St.3d 112 (reciprocal burden on nonmoving party to show triable issues)
- Vahila v. Hall, 77 Ohio St.3d 421 (summary judgment improper if material fact is genuinely disputed)
- Smiddy v. The Wedding Party, Inc., 30 Ohio St.3d 35 (appellate review of summary judgment stands in trial court's shoes)
- Continental W. Condominium Unit Owners Assn. v. Howard E. Ferguson, Inc., 74 Ohio St.3d 501 (settlement agreements are enforceable contracts terminating claims)
- State ex rel. Racing Guild of Ohio v. Morgan, 17 Ohio St.3d 54 (jurisdictional-priority rule between courts of concurrent jurisdiction)
- State ex rel. Phillips v. Polcar, 50 Ohio St.2d 279 (jurisdictional-priority rule principles)
- John Weenink & Sons Co. v. Cuyahoga Cty. Court of Common Pleas, 150 Ohio St. 349 (once court acquires jurisdiction its authority continues until final disposition)