Miami Valley Hosp. v. Middleton, 2011 Ohio 5069

Middleton, uninsured, was treated at Miami Valley Hospital after a September 25, 2008 auto accident and billed $5,573.10.
Hospital filed a case in Dayton Municipal Court for judgment on Middleton's account.
Middleton answered and filed a Civ.R. 14 third-party complaint against the alleged tortfeasor for damages and indemnity.
Hospital served discovery including admissions; Middleton did not respond, and Hospital moved for summary judgment on admissions.
Municipal Court dismissed the third-party complaint on December 29, 2009 and gave Middleton 14 days to respond to the summary judgment motion.
Middleton sought time to withdraw admissions and to conduct discovery; court granted 30 days to respond but later denied additional time and granted summary judgment for the Hospital in the amount of $3,905.94.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the municipal court properly dismissed the third-party complaint	Middleton	Middleton	Court did not abuse discretion; dismissal affirmed
Whether denial of leave to withdraw admissions was harmless	Middleton	Hospital	Harmless error; affirmed despite denial
Whether summary judgment was proper on reasonableness of charges	Middleton	Hospital	Summary judgment proper; bill prima facie evidence of reasonableness
Whether denial of additional discovery time was an abuse of discretion	Middleton	Hospital	No abuse of discretion; denial affirmed

Jacobs v. Municipal Court of Franklin County, 30 Ohio St.2d 239 (1972) ( Civ.R.14 third-party claims; trial court must assess propriety)
Robinson v. Bates, 112 Ohio St.3d 17 (2006) (medical bills as prima facie evidence of reasonableness; collateral-source rule context)
Sader v. St. Vincent Med. Ctr., 100 Ohio App.3d 379 (1995) (presumption that hospital charges are reasonable; admissibility of bills)
Renacci v. Martell, 91 Ohio App.3d 217 (1993) (derivative/common issues required for Civ.R.14 third-party claims)