Angler v. Muskingum Cty.

CourtOhio Court of Appeals
DecidedJune 2, 2026
DocketCT2025-0089
StatusPublished

This text of Angler v. Muskingum Cty. (Angler v. Muskingum Cty.) 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
Angler v. Muskingum Cty., (Ohio Ct. App. 2026).

Opinion

[Cite as Angler v. Muskingum Cty., 2026-Ohio-2058.]

IN THE OHIO COURT OF APPEALS FIFTH APPELLATE DISTRICT MUSKINGUM COUNTY, OHIO

ROBERT L. ANGLER, Case No. CT2025-0089

Plaintiff - Appellant Opinion And Judgment Entry

-vs- Appeal from the Muskingum County Court of Common Pleas, Case No. CH2022-0281 MUSKINGUM COUNTY, et al., Judgment: Affirmed Defendants - Appellees Date of Judgment Entry: June 1, 2026

BEFORE: Craig R. Baldwin; Robert G. Montgomery; David M. Gormley, Judges

APPEARANCES: LEWIS A. ZIPKIN, KEVIN M. GROSS, for Plaintiff-Appellant; ANDREW N. YOSOWITZ, SARAH A. LODGE, for Defendants-Appellees.

Baldwin, P.J.

{¶1} The appellant, Robert L. Angler, appeals the August 1, 2025, judgment entry

of the Muskingum County Court of Common Pleas granting summary judgment in favor

of the appellees, Dustin Prouty and Jeremy Archer, and dismissing the remaining claims

as untimely. The appellees are Dustin Prouty, Jeremy Archer, and Muskingum County.

STATEMENT OF FACTS AND THE CASE

{¶2} On October 11, 2022, the appellant filed a complaint in the Muskingum

County Court of Common Pleas arising from the appellant’s apprehension by law

enforcement.

{¶3} On January 9, 2023, the appellant filed a First Amended Complaint naming

the Muskingum County Board of Commissioners, Deputy Dustin Prouty, Deputy Jeremy Archer, and two unknown officers as defendants. The appellant asserted twelve claims.

Counts Eight and Nine, the claims pertinent to this appeal, were asserted against Archer

and Prouty, respectively. Those counts alleged that each deputy had an affirmative duty

to intervene and stop, prevent, or otherwise mitigate the use of excessive, unreasonable,

and unnecessary force against the appellant via K-9 Jango. The appellant further alleged

that Jango’s uninterrupted attack lasted longer than was necessary or reasonable to seize

the appellant and that the deputies acted recklessly, willfully, wantonly, maliciously, and

in bad faith.

{¶4} According to the filings, law enforcement officers were attempting to locate

and apprehend the appellant after he fled from authorities. Deputy Prouty, with his K-9

Jango, responded along with Deputy Archer.

{¶5} Deputy Prouty and another deputy warned that a K-9 would be released if

the appellant did not stop. The appellant did not stop. Deputy Prouty released Jango, who

bit the appellant’s left arm. The appellant alleged that the deputies should have called

Jango off sooner.

{¶6} The appellees moved for judgment on the pleadings. They argued, in part,

that Counts Eight and Nine were claims for battery and were barred by the one-year

statute of limitations contained in R.C. 2305.111(B). The trial court denied that portion of

the appellees’ motion, finding at the pleadings stage that the appellant could possibly

prove facts in support of a claim premised upon a duty owed to a person in custody.

{¶7} After the parties conducted discovery, the appellees moved for summary

judgment. Again, they argued that the essential character of the appellant’s remaining

claims sounded in assault or battery because the claims were predicated upon the alleged

use or continuation of excessive force during the appellant’s arrest. {¶8} The appellant opposed summary judgment. He maintained that Counts

Eight and Nine were custodial negligence claims governed by the two-year statute of

limitations in R.C. 2305.10, not the one-year limitations period applicable to assault and

battery. The appellant further argued that the deputies had a duty to protect him once

Jango had subdued him, and that their failure to timely command Jango to release was

negligent conduct separate from the initial release of the dog.

{¶9} On August 1, 2025, the trial court granted the appellees’ motion for

summary judgment, finding that Counts Eight and Nine were governed by the one-year

statute of limitations set forth in R.C. 2305.111(B). As the incident occurred on November

24, 2020, and the appellant did not file his complaint until October 11, 2022, the trial

court found the claims untimely and dismissed the case.

{¶10} The appellant filed a timely notice of appeal and raised the following

assignment of error:

{¶11} “I. BECAUSE PROUTY AND ARCHER FAILED TO EXERCISE

REASONABLE CARE BY TIMELY OUTING JANGO TO PROTECT ANGLER FROM

HARM, COUNTS EIGHT AND NINE ARE CUSTODIAL NEGLIGENCE CLAIMS

GOVERNED BY A TWO-YEAR STATUTE OF LIMITATIONS.”

I.

{¶12} In his sole assignment of error, the appellant argues that the trial court

erred in finding Counts Eight and Nine barred by the one-year statute of limitations

applicable to assault and battery. The appellant contends the claims are properly

characterized as custodial negligence claims because they are based upon the appellees’ failure to timely remove or “out” Jango after the appellant had been subdued. We

disagree.

STANDARD OF REVIEW

{¶13} We review a trial court’s decision granting summary judgment de novo.

Grafton v. Ohio Edison Co., 1996-Ohio-336. Summary judgment is appropriate when the

moving party demonstrates: (1) there is no genuine issue of material fact; (2) the moving

party is entitled to judgment as a matter of law; and (3) reasonable minds can come to

but one conclusion, and that conclusion is adverse to the non-moving party, who is

entitled to have the evidence construed most strongly in that party’s favor. Id.; Civ.R.

56(C).

{¶14} The determination of which statute of limitations applies to a claim is a

question of law, which we also review de novo. Timbuk Farms, Inc. v. Hortica Ins. &

Emple. Benefits, 2021-Ohio-4141, ¶50 (5th Dist.).

ANALYSIS

{¶15} R.C. 2305.111(B) provides that an action for assault or battery shall be

brought within one year after the cause of action accrues. R.C. 2305.10 generally provides

a two-year statute of limitations for bodily injury claims. The issue in this appeal is

whether the appellant’s remaining claims against the appellees, although framed as

custodial negligence claims on appeal, are governed by the one-year statute of limitations

period for assault and battery.

{¶16} The Supreme Court of Ohio addressed this issue in Love v. Port Clinton, 37

Ohio St.3d 98 (1988). In Love, the Court held that the essential character of an alleged

tort determines the applicable statute of limitations. The Court explained that where the

essential character of the alleged tort is an intentional, offensive touching, the statute of limitations for assault and battery applies even when the plaintiff pleads the touching as

negligence. Id. at 99.

{¶17} Here, the appellant’s First Amended Complaint repeatedly describes the

conduct at issue as the use of excessive, unreasonable, and unnecessary force. Count Eight

alleges Deputy Archer had an affirmative duty to “intervene and stop, prevent, or

otherwise mitigate the use of excessive, unreasonable, and unnecessary force against

Angler via Jango.” Count Nine contains substantially the same allegation against Prouty.

The appellant further alleges that Jango’s uninterrupted attack lasted for over thirty

seconds, was longer than necessary or reasonable to seize him, and lacked a legitimate

goal or justification. The injury alleged is the physical injury caused by Jango’s bite and

the continuation of that bite.

{¶18} The appellant attempts to distinguish the initial release of Jango from the

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Related

Love v. City of Port Clinton
524 N.E.2d 166 (Ohio Supreme Court, 1988)
Grafton v. Ohio Edison Co.
1996 Ohio 336 (Ohio Supreme Court, 1996)

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Bluebook (online)
Angler v. Muskingum Cty., Counsel Stack Legal Research, https://law.counselstack.com/opinion/angler-v-muskingum-cty-ohioctapp-2026.