Midland Funding, L.L.C. v. Ogunduyile, 2017 Ohio 9314

Defendant Ayo Ogunduyile opened a Credit One credit-card account in 2011; the account was charged off in 2013 and later purchased by Midland Funding, LLC.
Midland sued Ogunduyile in 2017 on an account, alleging a balance due of $877.75; Midland did not seek pre-judgment interest.
Midland attached to its complaint a July 2013 monthly statement showing a $877.75 balance and a chain‑of‑title showing assignment to Midland.
Ogunduyile was properly served, did not answer, and a default notice and motion for default judgment were filed.
Midland’s motion included an affidavit from a servicer employee stating the balance remained $877.75 as of February 14, 2017. The trial court entered default judgment for $877.75 plus costs.
On appeal (pro se) Ogunduyile challenged only the amount, arguing the card’s credit limit was $400 and he should only owe that amount; he did not dispute entry of default judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether default judgment was proper where defendant failed to answer	Midland: default appropriate under Civ.R. 55; complaint and supporting documents establish account balance	Ogunduyile: did not contest default entry (only amount)	Court: No abuse of discretion in entering default judgment when defendant did not defend
Whether the alleged $877.75 is a liquidated, provable amount	Midland: complaint, account statement, and servicer affidavit show an ascertainable balance of $877.75	Ogunduyile: credit limit was $400 so balance cannot be $877.75; prepared to pay $400	Court: Amount is liquidated/ascertainable; trial court properly relied on complaint and affidavit to award $877.75

Lykins v. Miami Valley Hosp., 811 N.E.2d 124 (Ohio Ct. App. 2004) (Civ.R. 55 permits default judgment when a defendant fails to appear)
Discover Bank v. Swartz, 51 N.E.3d 694 (Ohio Ct. App. 2016) (credit‑card balance may be liquidated if amount is ascertainable by agreement or arithmetic)