Williams v. State Farm Fire & Cas. Ins. Co.
2018 Ohio 57
| Ohio Ct. App. | 2018Background
- Karen Williams sued State Farm after a March 28, 2015 fire at her commercial property, alleging wrongful denial/voiding of her insurance claim.
- State Farm admitted it insured the property, that a fire occurred, and that it sent a denial/voidance letter; parties stipulated the policy was in effect and Williams timely reported the loss.
- Case proceeded to a jury trial; the jury returned a verdict for State Farm on June 8, 2017 and the trial court entered judgment June 15, 2017.
- Williams filed a pro se motion (and letter) alleging juror bias, evidentiary exclusion, misconduct, discrimination, and other trial irregularities; the trial court denied a new trial on July 18, 2017.
- On appeal Williams raised numerous complaints but did not provide a transcript of the trial proceedings or otherwise supply the record necessary to review her asserted errors.
- The appellate court treated her contentions as assignments of error but concluded it could not review them without the omitted transcript and affirmed the trial-court judgments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Juror bias | Jurors had policies with State Farm and were therefore biased | No specific rebuttal in opinion; focus on lack of record support | Appellate court refused to review bias claim because Williams did not provide trial transcript; presumes trial court proceedings valid |
| Evidentiary exclusions / witness denial | Williams asserts her tapes, witnesses, and evidence were improperly excluded | No record offered to show what was admitted or excluded | Court cannot evaluate alleged evidentiary errors without transcript; assignments of error overruled |
| Other misconduct (searching purse, discrimination, property retention) | Alleged adjuster/attorney misconduct, racial profiling, and that State Farm kept her computer | State Farm and trial court did not have these matters demonstrably in the appellate record | Court presumes regularity of proceedings absent transcript and affirms |
Key Cases Cited
- Knapp v. Edwards Laboratories, 61 Ohio St.2d 197 (1980) (appellant bears burden to provide record; omitted transcript requires presumption of regularity)
- Columbus v. Hodge, 37 Ohio App.3d 68 (10th Dist. 1987) (when necessary transcript portions are omitted, appellate court must presume validity of trial proceedings)