KeyBank, N.A., v. TroutmanKeyBank, N.A., v. Troutman
JUDGMENT: AFFIRMED
RELEASED AND JOURNALIZED: July 16, 2026
Appearances:
Weltman, Weinberg and Reis and Denise M. Leskovec, for appellee.
Holden Troutman, pro se.
EMANUELLA D. GROVES, J.:
{¶ 1} Defendant-appellant Holden Troutman (“Troutman“), pro se, appeals the trial court‘s decision granting default judgment in favor of plaintiff-appellee KeyBank, N.A. (“KeyBank“) and denying his motions to dismiss the
I. Facts and Procedural History
{¶ 2} In December 2024, KeyBank filed a complaint against Troutman for his failure to make payments according to the terms of a line-of-credit agreement. KeyBank sought a money judgment against Troutman for the principal sum and accrued interest. KeyBank attached the line-of-credit agreement and Troutman‘s account statement to the complaint.
{¶ 3} Troutman was served with a copy of the complaint on December 23, 2024, and a case-management conference was scheduled. Troutman did not answer or respond to the complaint. In March 2025, the case-management conference was cancelled and rescheduled as a default hearing. KeyBank was ordered to file a motion for default judgment along with an affidavit of damages and Troutman‘s military-service status, a proposed judgment entry, and a copy of the correspondence sent by KeyBank notifying Troutman of the date and time of the hearing via certified mail (collectively, “default-judgment documents“).
{¶ 4} KeyBank filed a motion for default judgment and a notice of filing, which included the following: a letter sent via ordinary and certified mail from KeyBank‘s counsel to Troutman informing him of the default hearing (“hearing letter“); an affidavit executed by KeyBank‘s counsel regarding the perfection of service upon Troutman (“service affidavit“); an affidavit executed by KeyBank‘s senior litigation specialist attesting to the amount due (“damages affidavit“); and an
{¶ 5} Troutman appeared for the default hearing, and a case-management conference was scheduled. The conference was held in June 2025, and Troutman was ordered to answer or respond to the complaint prior to the next default hearing, which was set for July 2025. Troutman was warned that judgment may be entered against him if he failed to comply, and KeyBank was again ordered to file the default-judgment documents. The trial court‘s journal entry noted that notice was issued.
{¶ 6} In July 2025, KeyBank filed another notice of filing and attached an updated hearing letter, damages and military affidavits, and a proposed judgment entry. Troutman did not answer or respond to the complaint, and the default hearing was held. The trial court issued a final judgment entry on July 30, 2025, awarding judgment to KeyBank and against Troutman in the amount of “the principal sum of $75,806.90, plus accrued interest in the amount of $4,843.01, and its costs herein.” Therein, the trial court noted “that defendant was given prior notice and an opportunity for a judicial hearing at which [Troutman] could assert defenses to [KeyBank‘s] claim.”
{¶ 7} In August 2025, Troutman filed a motion to set aside the default judgment pursuant to
{¶ 8} The trial court scheduled another default hearing in September 2025. Prior to the hearing, Troutman filed a motion to dismiss the complaint pursuant to
{¶ 9} In October 2025, KeyBank filed a brief in opposition to Troutman‘s motions. KeyBank countered that the complaint was properly served upon Troutman and discussed Troutman‘s participation in the case. KeyBank emphasized that the trial court gave Troutman “more than enough” notice, deference, and time to comply with its rules and orders — including holding a case-management conference in June 2025 and permitting him to file an answer prior to the July 2025 default hearing — however, Troutman failed to comply.
{¶ 10} On November 3, 2025, the trial court denied Troutman‘s
{¶ 11} On December 1, 2025, Troutman filed a notice of appeal. Troutman indicated that he would be filing an
The trial court erred and abused its discretion by entering default judgment when [KeyBank] failed to comply with the court‘s pre-hearing order and the requirements of
Assignment of Error No. 2
The trial court erred in denying [Troutman‘s] motion to set aside the default judgment under
Assignment of Error No. 3
The trial court erred in accepting and enforcing a complaint and unauthenticated exhibits that did not meet the requirements of
Assignment of Error No. 4
The trial court abused its discretion by not affording reasonable latitude to a pro se litigant and by denying relief in a manner inconsistent with due process under the Ohio Constitution and Ohio case law.
II. Law and Analysis
{¶ 12} As an initial matter, we note that Troutman acted pro se in the proceedings below and is acting pro se in the instant appeal. “‘It is well established that pro se litigants are presumed to have knowledge of the law and legal procedures and that they are held to the same standards as litigants who are represented by counsel.‘” State ex rel. Fuller v. Mengel, 2003-Ohio-6448, ¶ 10, quoting Sabouri v. Ohio Dept. of Job & Family Servs., 145 Ohio App.3d 651, 654 (10th Dist. 2001). Indeed, “‘[p]ro se litigants are not entitled to greater rights, and they must accept the results of their own mistakes.‘” Fazio v. Gruttadauria, 2008-Ohio-4586, ¶ 9
A. Jurisdictional Issues
{¶ 13} Since “[t]his court has a duty to examine, sua sponte, potential deficiencies in jurisdiction,” we begin our analysis with the jurisdictional issues presented by Troutman‘s first and third assignments of error. Cooney v. Radostitz, 2021-Ohio-2521, ¶ 12 (8th Dist.).
{¶ 14} An order is considered final when it “affects a substantial right in an action that in effect determines the action and prevents a judgment.”
{¶ 15} Generally, a trial court loses jurisdiction over the substantive merits of a case after entering a final judgment. Miles v. Cleveland Clinic Health Sys.-E. Region, 2026-Ohio-190, ¶ 8 (8th Dist.), citing State ex rel. Mather v. Oda, 2023-Ohio-3907, ¶ 1; Phoenix Lighting Group, L.L.C. v. Genlyte Thomas Group, L.L.C., 2024-Ohio-5729, ¶ 20 (“A trial court‘s jurisdiction over a matter is limited once proceedings are complete.“). Absent specific authority prescribed by the Ohio Rules of Civil Procedure, a trial court may not continue to act after a case has ended; any
{¶ 16} An appeal from a final order must be filed within 30 days of its entry.
{¶ 17} Here, the July 30, 2025 journal entry is a final order: it disposed of “the whole merits of the cause” by (1) rendering a default judgment against Troutman and in favor of KeyBank on its complaint and (2) determining the amount of damages. Therefore, the trial court lost jurisdiction over the case‘s substantive merits; it could not adjudicate the complaint again by holding a subsequent default hearing or ruling on Troutman‘s
{¶ 18} “Bootstrapping” occurs when an error is assigned “‘from a final order that was not the subject of a timely notice of appeal’ in an ‘otherwise timely appeal.‘” Plaza v. Roberts, 2024-Ohio-3021, ¶ 16 (8th Dist.), quoting Basit v. Chapman, 2016-Ohio-App. LEXIS 2399, *2-3 (8th Dist. June 23, 2016). “This court has ‘consistently refused’ to address ‘bootstrapped’ assignments of error” since the practice “is procedurally anomalous and inconsistent with the appellate rules which contemplate a direct relationship between the order from which the appeal is taken and the error assigned as a result of that order.” (Cleaned up.) Id., citing Basit and Chapon v. Std. Contracting & Eng., 2007-Ohio-4306, ¶ 3 (8th Dist.).
{¶ 19} Moreover, it “has been long-accepted by Ohio courts” that a party may not utilize a
{¶ 20} Here, Troutman‘s appeal from the denial of his
B. Civ.R. 60(B) Denial and Due Process for Pro Se Litigants
{¶ 21} Next, we turn to Troutman‘s second and fourth assignments of error. In his second assignment of error Troutman challenges the trial court‘s denial of his
{¶ 22} After reviewing his appellate brief, we acknowledge that Troutman cites rules, case law, and
{¶ 23} For example, Troutman cites GTE Automatic Elec., Inc. v. ARC Industries, Inc., 47 Ohio St.2d 146 (1976), to recite the three elements a movant must establish to be entitled to
{¶ 24} Troutman also cites
{¶ 25}
{¶ 26} Indeed, it is well settled that appellate courts are not advocates, and appellants bear the burden of constructing the legal arguments necessary to support their assignments of error. Id., citing Taylor-Stephens v. Rite Aid of Ohio, 2018-Ohio-4714, ¶ 121 (8th Dist.), and Doe v. Cuyahoga Cty. Community College, 2022-Ohio-527, ¶ 26 (8th Dist.). “‘If an argument exists that can support [an] assigned error, it is not this court‘s duty to root it out.‘” Strauss v. Strauss, 2011-Ohio-3831, ¶ 72 (8th Dist.), quoting Cardone v. Cardone, 1998-Ohio-App. LEXIS 2028, *22 (9th Dist. May 6, 1998).
{¶ 27} The burden rests with Troutman to establish the validity of his assignments of error; yet he provides this court with minimal guidance or support for his positions. Therefore, we decline to review Troutman‘s second and fourth assignments of error.
{¶ 28} However, we note that even if we were to address the merits of Troutman‘s appeal, we would find that the trial court properly denied his
{¶ 29} Nor does Troutman offer any explanation as to why he was unable to apprise himself of deadlines and court dates by checking the docket; rather he shifts blame to the trial court and KeyBank, claiming that he was not properly served with notice of the default hearing. However, in addition to the court‘s own notification system, KeyBank filed default-judgment documents — which included hearing letters — in compliance with the trial court‘s orders on several occasions. Even on appeal, Troutman‘s contentions regarding the grounds entitling him to relief do not contemplate his own neglectful acts or mistakes; rather, he focuses solely on KeyBank‘s purported failures. Consequently, we cannot say that the trial court abused its discretion when it denied Troutman‘s
{¶ 30} Accordingly — and in the absence of any authority cited to the contrary — we overrule his second and fourth assignments of error and affirm the trial court‘s decision.
{¶ 31} Judgment affirmed.
It is ordered that appellee recover from appellant costs herein taxed.
The court finds there were reasonable grounds for this appeal.
A certified copy of this entry shall constitute the mandate pursuant to
EMANUELLA D. GROVES, JUDGE
LISA B. FORBES, P.J., and
EILEEN A. GALLAGHER, J., CONCUR