Al Castrucci Ford Sales, Inc. v. Thompson

7 Ohio App. Unrep. 519
CourtOhio Court of Appeals
DecidedOctober 15, 1990
DocketCase No. CA89-09-077
StatusPublished

This text of 7 Ohio App. Unrep. 519 (Al Castrucci Ford Sales, Inc. v. Thompson) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Al Castrucci Ford Sales, Inc. v. Thompson, 7 Ohio App. Unrep. 519 (Ohio Ct. App. 1990).

Opinion

Per Curiam.

This is an appeal by plaintiff-appellant, A1 Castrucci Ford Sales, Inc, from a judgment of the Clermont County Court in favor of defendant-appellee, James P. Thompson.

A1 Castrucci Ford Sales, Inc ("Castrucci") is an Ohio corporation that operates a car dealership known as A1 Castrucci Ford. On March 11, 1986, Thompson took his truck, which had previously been purchased from Castrucci Ford, to the dealership for repairs. Kenneth Castrucci, Castrucci's vice president, called Thompson on April 10, 1986 and told him that repairs had been completed and that he should pick up his truck. Thompson informed him that the truck was still not running properly. Kenneth Castrucci examined the truck and found none of the problems of which Thompson complained. The following day, he called Thompson and told him to remove the truck or else he would charge him for storage. Thompson denies having any conversation with Kenneth Castrucci. On April 29, 1986, Thompson filed a breach of warranty suit against Castrucci seeking to rescind the purchase contract for the truck due to alleged defects Thompson finally removed the truck from Castrucci Ford's parking lot on June 4, 1987. Because he felt the problems with the truck had been corrected, he dismissed his suit against Castrucci with prejudice On June 10, 1987.

On March 22, 1988, Castrucci filed a complaint against Thompson seeking to recover storage charges and damages for trespass Thompson filed an answer denying the substantive allegations of the complaint. Prior to trial, the trial court raised the issue of whether Castrucci's claim was barred by res judicata, specifically whether it was a compulsory counterclaim pursuant to Civ. R. 13(A) which should have been brought in the prior suit filed by Thompson. Thompson did not plead the defense of res judicata in his answer. On January 6, 1988, the day of trial, he made an oral motion [520]*520to dismiss based on res judicata. Castrucci opposed the motion on the ground that the defense had not been pleaded. At the court's request, the parties submitted joint exhibit 1, a copy of the complaint and notice of dismissal in the prior suit. The factual issues were then tried but little reference was made to the prior suit.

After trial the parties submitted memo-randa regarding the issue of res judicata, which were requested by the trial court. At that time, Thompson filed a motion to amend his answer to conform to the evidence presented at trial pursuant to Civ. R. 15 (B) to include the defense of res judicata. Castrucci opposed this motion.

The trial court issued a written decision stating that Thompson was entitled to file an amended answer setting forth additional defenses and that the court had considered those defenses in rendering its decision. It found that Castrucci's complaint was a mandatory counterclaim in the prior suit and that it was therefore barred. This appeal followed.

In its sole assignment of error, Castrucci states that the trial court erred by entering judgment in favor of Thompson on the basis that its claim was a compulsory counterclaim which should have been raised in the prior action. Castrucci argues that its claim for storage charges was not complete at the time of the prior suit and that its claim did not arise from the same transaction that was the subject of the prior suit. It further argues that Thompson waived the defense of res judicata. We find this assignment of error is not well-taken.

Civ. R. 13(A) provides in pertinent part:

"*** A pleading shall state as a counterclaim any claim which at the time of serving the pleading the pleader has against any opposing party, if it arises out of the transaction or occurrence that is the subject matter of the opposing party's claim and does not require for its adjudication the presence of third parties of whom the court cannot acquire jurisdiction.

An unasserted compulsory counterclaim is barred in any subsequent suit by the doctrine of res judicata. Geauga Truck & Implement Co. v. Juskiewicz 24 (1984), 9 Ohio St; 3d 12, 14; Quintus v. McClure (1987), 41 Ohio App. 3d 402, 403-04. The Ohio Supreme Court has set forth a two-pronged test for determining whether a claim is a compulsory counterclaim under Civ. R. 13(A): "(1) does the claim exist at the time of serving the pleading ***, and (2) does the claim arise out of the transaction or occurrence that is the subject matter of the opposing claim." Geauga Truck, supra, at 14.

Thompson filed his complaint against Castrucci on April 29, 1986. Castrucci filed its answer in that action on May 28, 1986 but did not file a counterclaim. In the present case, Castrucci alleged in its complaint that storage charges were owed from the date that Thompson "was notified that Castrucci had completed its work on the truck," which was April 10, 1986. Castrucci's claim for storage charges existed at the time it filed its answer to Thompson's complaint on May 28, 1986. Accordingly, the first prong of the test is satisfied.

As to the second prong of the test, courts interpreting Fed. R. Civ. R 13(a), which is identical to the Ohio rule, have generally agreed that the words "transaction or occurrence" should be liberally interpreted to carry out the purpose of the rule, which is to avoid a multiplicity of suits. Warshawsky & Co. v. Arcata National Corp. (C.A.7, 1977), 552 F.2d 1257, 1261; see also, Maduka v. Parries (1984), 14 Ohio App. 3d 191, 192-93. Accordingly, the factual backgrounds of the claims need not be identical as long as they are logically related. Maduka, supra, at 193; McCord v. Costy (Dec 7, 1987), Clermont App. No. CA87-05-036, unreported. "Although several tests have been suggested, primary focus is attached to a flexible test of reviewing the transaction to determine whether there is any logical relationship between the claim and the counterclaim." Eastman v. Benchmark Minerals, Inc. (1986), 34 Ohio App. 3d 255, 257.

In the prior suit, Thompson alleged that defects in the truck constituted "a non-conformity with the express warranty provided by [Castrucci] to [Thompson], as well as implied warranties of merchantability and fitness for a particular purpose" It also alleged that he had provided Castrucci with notice that he wished to rescind the purchase contract for the truck due to its defective condition. In the present case, Thomp-son testified that he left the truck on Castrucci's lot because the defects had not been repaired and that he had intended to leave it there until it was satisfactorily repaired. He also testified that he never received a call from Castrucci telling him to remove his truck or he would be assessed storage charges. Under the circumstances, we find that the issue of whether [521]*521storage charges and damages for trespass were justified is logically related to the issue of whether the truck was defective and whether these defects were adequately repaired.

Castrucci argues that since in the prior action Thompson alleged that he gave notice to Castrucci of his intent to rescind the purchase contract on April 11, 1986, the facts at issue in that suit necessarily occurred prior to that date. However, Castrucci's claims relate solely to events after April 11, 1986, when Castrucci allegedly told Thompson to remove his truck from Castrucci's premises or incur storage charges.

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Related

Maduka v. Parries
470 N.E.2d 464 (Ohio Court of Appeals, 1984)
Eastman v. Benchmark Minerals, Inc.
518 N.E.2d 23 (Ohio Court of Appeals, 1986)
Johnson v. Linder
471 N.E.2d 815 (Ohio Court of Appeals, 1984)
Quintus v. McClure
536 N.E.2d 22 (Ohio Court of Appeals, 1987)
Northfield Park Associates v. Northeast Ohio Harness
521 N.E.2d 466 (Ohio Court of Appeals, 1987)
Clark v. Baranowski
145 N.E. 760 (Ohio Supreme Court, 1924)
State ex rel. Auto Loan Co. v. Jennings
237 N.E.2d 305 (Ohio Supreme Court, 1968)
State ex rel. Evans v. Bainbridge Township Trustees
448 N.E.2d 1159 (Ohio Supreme Court, 1983)
Hall v. Bunn
464 N.E.2d 516 (Ohio Supreme Court, 1984)
Hoover v. Sumlin
465 N.E.2d 377 (Ohio Supreme Court, 1984)
Spisak v. McDole
472 N.E.2d 347 (Ohio Supreme Court, 1984)

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Bluebook (online)
7 Ohio App. Unrep. 519, Counsel Stack Legal Research, https://law.counselstack.com/opinion/al-castrucci-ford-sales-inc-v-thompson-ohioctapp-1990.