Jackson v. Friedlander, 2016 Ohio 7503

Laura Jackson, administratrix of Larry Jackson's estate, sued Dr. Ira Friedlander, Ohio Physicians Professional Corporation, and Aultman Hospital for wrongful death alleging negligent post‑operative care after a pacemaker implantation at Aultman (Stark County); decedent died in Wayne County of a pulmonary embolism after discharge.
Defendants moved to transfer venue from Wayne County to Stark County; the Wayne County Common Pleas Court granted the transfer and sent the case to Stark County.
Jackson filed a motion in Stark County to reject the change of venue, arguing wrongful death "part of the claim" arose in Wayne County because the decedent died there; the Stark trial court denied the motion.
The case proceeded to jury trial in Stark County; the jury returned a verdict for defendants and judgment was entered in February 2016.
On appeal, Jackson challenged only the venue transfer and asked the appellate court to reverse and remand with instructions to transfer the case back to Wayne County.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the venue transfer from Wayne to Stark was erroneous in a wrongful‑death action where decedent died in Wayne County	Jackson: Wrongful‑death claim "part of the claim" arose in Wayne County because death occurred there, so venue in Wayne was proper and transfer was improper	Defs: Civil Rule 3(G) prohibits voiding a final judgment solely on venue grounds and limits appeals based solely on venue	The appeal, which attacked only venue and sought to void the final judgment, was barred by Civ.R. 3(G); court affirmed Stark County judgment

State ex rel. Lyons v. Zaleski, 75 Ohio St.3d 623 (Ohio 1996) (denial or grant of change of venue is not a final, appealable order)
LaNeve v. Atlas Recycling, Inc., 119 Ohio St.3d 324 (Ohio 2008) (civil rules are not mere technicalities and must be applied according to plain language)