Johnson Invest. Group, L.L.C. v. Marcum, 2013 Ohio 3175

Johnson Investment Group, LLC (dba Fairborn Transmission Service) performed transmission repairs and follow-up service on Marcum’s 1999 Dodge pickup after oral estimates were given at Johnson’s mother’s house.
First repair: oral estimate $2,500 plus tax; billed $2,552.22. Second job: estimated ~$400 plus tax; billed $428.98. Marcum agreed to both estimates and left the truck for repairs.
Johnson (majority owner of the LLC and sole estimator) repeatedly asked Marcum for payment; Marcum promised to pay but delayed. Written invoices were not delivered until about a year later.
Plaintiff sued in municipal court for unpaid repair charges; defendant denied liability, raised defenses, and pled counterclaims (later dismissed).
Magistrate found for plaintiff for $2,981.20; trial court overruled defendant’s objections and entered judgment for the same amount. Defendant appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing — Is Johnson Investment Group the proper party?	LLC (Johnson) acted through its business; repairs were performed by the shop; plaintiff is the rightful creditor.	Conversations and transactions occurred at Johnson’s mother’s home and between Marcum and Johnson personally, so any agreement was with Johnson individually, not the LLC.	Court held LLC had standing: Johnson acted in his capacity as owner of the business; services were performed by the shop, and there was no evidence the work was a personal favor or gift.
Existence of an enforceable contract — Was there a meeting of the minds on price?	Oral estimates were given and accepted; work was performed as agreed; prices were reasonable and customary.	No meeting of the minds on essential terms (price), so no enforceable contract.	Court held valid oral contracts existed for both repair events: offer, acceptance, and performance were established.

Fortner v. Thomas, 22 Ohio St.2d 13 (standing requires an actual controversy and personal stake)
Kincaid v. Erie Ins. Co., 128 Ohio St.3d 322 (standing is a threshold inquiry reviewed de novo)
Fed. Home Loan Mtge. Corp. v. Schwartzwald, 134 Ohio St.3d 13 (lack of standing requires dismissal; standing is jurisdictional)
Minster Farmers Coop. Exchange Co., Inc. v. Meyer, 117 Ohio St.3d 459 (elements and formation of contract)
Kostelnik v. Helper, 96 Ohio St.3d 1 (contract elements and enforceability)
Episcopal Retirement Homes, Inc. v. Ohio Dept. of Indus. Relations, 61 Ohio St.3d 366 (meeting of the minds as required for contract formation)