Sycamore Twp. v. Carr, 2022 Ohio 1337

Sycamore Township sued to enjoin political campaign signs on a parcel owned by the Sohi Trust; initial defendants included Carr and the trustee, later amended.
Dr. Parneet Sohi and Friends of Sohi intervened in 2018 (Sohi was a trust beneficiary; Friends had a political interest in the signs).
Parties executed an August 2020 settlement: stipulated dismissal with prejudice, sign modifications by the Sohi Trust, and settlement payments allocated to defendants and their attorneys.
Joint dismissal filed in October 2020, but Township moved to enforce the settlement in March 2021, alleging defendants reneged.
Defendants’ attorneys moved to withdraw; the trial court granted withdrawal after counsel gave notice, obtained a stipulated extension, and the court later held a hearing and enforced the settlement (including permitting sign removal).
Sohi appealed pro se, arguing (1) attorneys who were to receive fees under the settlement were necessary parties and should have been joined, and (2) the court erred in allowing counsel to withdraw.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether former counsel were necessary parties to a motion to enforce because the settlement allocated fees to them	No joinder required; enforcement could focus on defendants’ performance	Attorneys had an interest in the fees and thus should have been joined	Sohi waived the argument by not raising it below; even if preserved, counsel were not parties to the settlement and joinder was unnecessary
Whether the trial court abused its discretion in granting counsel's motion to withdraw	Withdrawal was proper because counsel gave notice, secured an extension, and took steps to avoid prejudice	Withdrawal prejudiced Sohi and violated the spirit of the Rules of Professional Conduct	No abuse of discretion: counsel provided notice, negotiated an extension, and Sohi had two months to obtain new counsel

Bennett v. Bennett, 86 Ohio App.3d 343 (8th Dist. 1993) (trial court abused discretion by allowing withdrawal without reasonable steps to prevent client prejudice)
J. Bowers Constr. Co. v. Gilbert, 18 N.E.3d 770 (9th Dist. 2014) (party not a necessary or indispensable party where no contract or obligation existed between plaintiff and that party)