Teague v. Schmeltzer
2018 Ohio 76
| Ohio Ct. App. | 2018Background
- Constance and Julius Schmeltzer died in 2012–2013; their three adult children (Kathleen Teague, Steven Schmeltzer, Ernest Schmeltzer) were beneficiaries of living trusts.
- Kathleen (as executrix) sued Steven seeking return of estate assets; Steven filed for declaratory relief; related probate matters were consolidated under 2015-CV-006.
- The parties reached a preliminary settlement at mediation (Oct. 19, 2016) requiring Old Portage Company to pay Ernest $30,000 and dismissal of the litigation upon a final agreement; a final settlement was later signed by all parties.
- Ernest later moved to enforce the settlement, sought sanctions, then filed to withdraw his signature and for contempt after a Texas Attorney General child-support lien attached to the $30,000; he alleged the lien resulted from improper contact by other parties.
- The probate court denied Ernest’s motions (March 10, 2017) and later entered a dismissal with prejudice under the settlement (April 10, 2017). Ernest appealed only the April 10 dismissal; the appellate court amended the appeal to include that order and dismissed the earlier interlocutory appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred by denying Ernest’s motion to enforce settlement, for sanctions, and to withdraw his signature without an evidentiary hearing | Ernest: the lien and alleged misconduct created factual disputes (fraud/misrepresentation) requiring an evidentiary hearing before denying enforcement or permitting withdrawal | Teague/Steven: Ernest signed the final agreement, does not dispute its terms; the lien is external and does not create a dispute about existence or terms of the settlement | Court: No evidentiary hearing required; Ernest raised no factual dispute about existence or terms of the settlement; denial affirmed |
| Whether the court erred by granting a dismissal with prejudice under the settlement without an evidentiary hearing | Ernest: dismissal should not proceed while he disputes enforcement/withdrawal due to lien and alleged misconduct | Teague/Steven: settlement was signed by all parties and authorized dismissal; any lien issue is collateral and must be litigated elsewhere | Court: Dismissal proper under signed settlement; no abuse of discretion for not holding a hearing |
Key Cases Cited
- Rulli v. Fan Co., 79 Ohio St.3d 374 (1997) (an evidentiary hearing is required when there is a factual dispute about whether a settlement was reached or whether the written document reflects the agreement)
- Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (abuse of discretion standard: decision is an abuse only if unreasonable, arbitrary, or unconscionable)
- Pons v. Ohio State Med. Bd., 66 Ohio St.3d 619 (1993) (appellate courts should not substitute their judgment for the trial court’s when reviewing discretionary matters)