State ex rel. Clinton v. MetroHealth Sys.
2017 Ohio 2855
| Ohio Ct. App. | 2017Background
- Karen Clinton, pro se, sought relief from a judgment that granted MetroHealth summary judgment in a public-records/mandamus dispute and appealed the denial of her Civ.R. 60(B) motion.
- This appeal followed two earlier appellate decisions adverse to Clinton (referred to as Clinton I and Clinton II); Clinton argued those prior rulings were erroneous and sought to relitigate issues via 60(B).
- The trial court denied Clinton’s Civ.R. 60(B) motion, relying on this court’s prior decision in Clinton II.
- The court limited its review to Clinton’s first assignment of error (challenge to denial of 60(B)), treating the remaining assignments as attempts to relitigate prior, final rulings.
- The court applied the Civ.R. 60(B) standard (meritorious claim, applicable ground under Civ.R. 60(B)(1)–(5), and reasonable timing) and the doctrine of res judicata to affirm denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court abused its discretion by denying Clinton’s Civ.R. 60(B) motion | Clinton argued the trial court improperly relied on this court’s Clinton II decision and that genuine factual disputes (delay, withholding, destruction of records) warranted relief | MetroHealth argued the 60(B) motion rehashed issues already decided in Clinton II and did not present newly discovered evidence or a meritorious, timely basis for relief | Denial affirmed: court found Clinton offered no new evidence, did not meet Civ.R. 60(B) elements, and the motion was barred by res judicata |
| Whether Clinton’s claims were barred by res judicata | Clinton contended prior appellate rulings were erroneous and sought reconsideration via 60(B) | MetroHealth asserted the prior final judgment on the merits bars relitigation of the same claims | Held that prior final judgment bars subsequent actions arising from the same transaction; res judicata applies |
| Whether summary judgment for MetroHealth was improper because factual disputes existed | Clinton claimed summary judgment was inappropriate because issues of delay and destruction of records created factual disputes | MetroHealth maintained claims were untimely, barred, speculative, confidential, or unclear as previously adjudicated | Court sustained prior conclusion that summary judgment was proper in Clinton II; issues already decided |
| Whether Clinton presented a meritorious claim or new evidence under Civ.R. 60(B) | Clinton asserted errors in prior rulings and factual issues but did not present newly discovered evidence | MetroHealth contended Clinton presented no new, previously unavailable evidence and failed to satisfy Civ.R. 60(B) requirements | Court held Clinton did not demonstrate a meritorious claim or newly discovered evidence; Civ.R. 60(B) relief denied |
Key Cases Cited
- Strack v. Pelton, 70 Ohio St.3d 172 (Ohio 1994) (abuse-of-discretion standard for review of relief-from-judgment rulings)
- GTE Automatic Elec. v. ARC Indus., Inc., 47 Ohio St.2d 146 (Ohio 1976) (three-prong test for Civ.R. 60(B) relief)
- Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio 1983) (definition of abuse of discretion)
- Grava v. Parkman Twp., 73 Ohio St.3d 379 (Ohio 1995) (res judicata bars subsequent actions arising from same transaction)
- Portage Cty. Bd. of Commrs. v. Akron, 109 Ohio St.3d 106 (Ohio 2006) (elements of claim preclusion/res judicata)
- Hapgood v. Warren, 127 F.3d 490 (6th Cir. 1997) (federal formulation of res judicata elements cited by Ohio courts)