Ohio Civ. Rights Comm. v. Lyons
2016 Ohio 7174
| Ohio Ct. App. | 2016Background
- Hannah (intervenor) alleged landlords Doris and Charles Lyons refused to rent after a phone exchange suggesting race influenced their decision; Ohio Civil Rights Commission filed suit under Ohio fair-housing statutes.
- The parties mediated and settled all merits claims: Lyons paid Hannah $9,000, reimbursed costs, agreed on training, and the case was dismissed with prejudice; the mediated notes expressly stated "no admission and no finding of liability/guilt" and that a fee award was not mandatory, but allowed Hannah to apply for fees.
- Hannah filed an application for $32,838 in attorney’s fees under R.C. 4112.051(D), arguing the statute must be liberally construed and that she was a prevailing party by settlement.
- Defendants contested fees, reiterating they had not admitted liability; they also filed a renewed statute-of-limitations dismissal (which the trial court did not reach after settlement).
- The trial court denied fees, reasoning R.C. 4112.051(D) mandates fees only where a court or jury finds a violation; no such finding occurred because the case settled with no admission.
- The appellate court affirmed, holding the statute’s plain language restricts mandatory fee awards to situations with a judicial finding of violation and the legislature deliberately chose narrower language than comparable federal statutes.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether R.C. 4112.051(D) permits an award of attorney's fees after settlement where no court or jury found a violation | R.C. 4112 should be liberally construed; Hannah prevailed via settlement and preserved right to seek fees in mediation | The statute requires a court or jury finding of a violation; settlement contains "no admission/no finding" and fees were not mandatory | Court: Fees denied — R.C. 4112.051(D) applies only when a court or jury finds a violation, and no such finding existed here |
Key Cases Cited
- Maher v. Gagne, 448 U.S. 122 (U.S. 1980) (party may be deemed a "prevailing party" for fee awards under certain federal statutes by vindicating rights through settlement)