Taddeo v. Bodanza, 2014 Ohio 3719

Taddeo opened two ONESCO accounts in 2004, with Bodanza as ONESCO’s registered representative and sole owner of PFS; Takacs also did business as a registered representative for ONESCO.
In 2006 Bodanza sought private securities transactions; ONESCO advised against it, leading Bodanza to resign from ONESCO and surrender his license to pursue PFH oil-and-gas ventures.
Bodanza informed Taddeo in December 2007 that PFH bonds would be offered; Taddeo instead purchased two PFH promissory notes totaling $230,000.
In 2010 PFH defaulted; Taddeo filed a 2011 complaint asserting multiple claims across insurance, securities, and tax preparer theories.
The trial court granted summary judgment to all defendants on all claims in November 2013; the matter then proceeded on appeal.
On appeal, the court reviewed the assignments de novo and overruled several due to lack of legal argument or authority, affirming judgment for the defendants.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Liability for unregistered securities (Bodanza).	Taddeo asserts Bodanza sold unregistered securities and is strictly liable for refunds.	Bodanza contends no viable basis as pleaded; arguments not properly linked to asserted causes of action.	Assignment I overruled; no proper argument linking to a viable claim.
ONESCO liability based on expert report opposing summary judgment.	Expert report creates a genuine issue of material fact for ONESCO's liability.	No argument establishing Bodanza’s liability; respondeat superior insufficient without agent liability.	Assignment II overruled; no genuine issue as to ONESCO’s liability.
Takacs participation in sale of unregistered securities.	Takacs aided sale by obtaining signatures and funds for investment under PFS.	No viable legal theory identified; lacks supporting authority.	Assignment III overruled.
PFS liability for aiding sale of unregistered securities.	PFS conducted business at PFH’s address and treated Taddeo as a client.	No legal authority linking these facts to a viable claim.	Assignment IV overruled.
ONESCO control over operations/publicity and vicarious liability.	ONESCO had authority over PFS operations and publicity.	No authority-based argument presented.	Assignment V overruled.

Dresher v. Burt, 75 Ohio St.3d 280 (Ohio 1996) (Dresher standard for movant's showing on summary judgment)
Baiko v. Mays, 140 Ohio App.3d 1 (8th Dist. 2000) (summary judgment framework for opposing party)
Natl. Union Fire Ins. Co. v. Wuerth, 122 Ohio St.3d 594 (Ohio 2009) (vicarious liability requires direct agency liability)
Gilbert v. Summit Cty., 104 Ohio St.3d 660 (Ohio 2004) (summary judgment standard and de novo review)
Roth v. Roth, 8th Dist. Cuyahoga No. 89141 (Ohio 2008) (appellate review standards for assignments of error)