Ashtabula Cty. Med. Ctr. v. Porter

2025 Ohio 803
CourtOhio Court of Appeals
DecidedMarch 10, 2025
Docket2024-A-0067
StatusPublished

This text of 2025 Ohio 803 (Ashtabula Cty. Med. Ctr. v. Porter) 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
Ashtabula Cty. Med. Ctr. v. Porter, 2025 Ohio 803 (Ohio Ct. App. 2025).

Opinion

[Cite as Ashtabula Cty. Med. Ctr. v. Porter, 2025-Ohio-803.]

IN THE COURT OF APPEALS OF OHIO ELEVENTH APPELLATE DISTRICT ASHTABULA COUNTY

ASHTABULA COUNTY CASE NO. 2024-A-0067 MEDICAL CENTER,

Plaintiff-Appellant, Civil Appeal from the Court of Common Pleas - vs -

STEPHEN D. PORTER, Trial Court No. 2023 CV 00346

Defendant,

MEGAN D. PORTER,

Defendant-Appellee.

OPINION

Decided: March 10, 2025 Judgment: Affirmed

Dan A. Morell, Jr. and John J. Schneider, Dan Morell & Associates, LLC, 6060 Rockside Woods Boulevard, N., Suite 200, Independence, OH 44131 (For Plaintiff-Appellant).

William E. Riedel and Katherine S. Riedel, Law Offices of Katherine S. Riedel, 1484 State Route 46 North, Jefferson, OH 44047 (For Defendant-Appellee).

EUGENE A. LUCCI, J.

{¶1} Appellant, Ashtabula County Medical Center (“ACMC”) appeals the

judgment of the Ashtabula County Court of Common Pleas, concluding any claim it may

have against appellee, Megan D. Porter, in an action for money damages on medical

debts, filed pursuant to R.C. 3103.03, Ohio’s “necessaries statute” is currently

hypothetical and therefore not a justiciable matter. We affirm. {¶2} At the inception of the case, Stephen D. Porter (Ms. Porter’s ex-husband)

had been employed at Dasco Paper & Janitorial Supply in Ashtabula, Ohio, for

approximately eight years. Mr. Porter and Ms. Porter were married on July 2, 2015. On

March 7, 2021, their marriage was dissolved. During the marriage, and after March 7,

2021, Mr. Porter incurred medical expenses from ACMC in the amount of $12,925.55. In

total, Mr. Porter incurred medical expenses of $6,416 prior to March 7, 2021 and

$6,059.55 after March 7, 2021.

{¶3} ACMC filed a complaint on June 1, 2023, to collect upon medical expenses

provided to Mr. Porter between July 20, 2017 and October 5, 2022. ACMC alleged, inter

alia, the Porters were responsible to pay the cost of the medical services provided under

R.C. 3103.03. ACMC’s complaint demanded judgment against Mr. Porter in the amount

of $12,925.55 and $6,416 against Ms. Porter.

{¶4} Ms. Porter answered ACMC’s complaint and denied the allegations; she

also filed a cross-claim against Mr. Porter for unjust enrichment, wherein she admitted

that she and Mr. Porter were married on July 2, 2015 and the marriage dissolved on

March 7, 2021. Mr. Porter did not answer the complaint but appeared for scheduled

mediation. ACMC acknowledges that Mr. Porter’s debt in 2022, after the dissolution of

the marriage, was eligible for charity-care coverage.

{¶5} Mediation occurred in March and April 2024, during which Mr. Porter and

ACMC resolved ACMC’s claim against him. A consent judgment entry was submitted to

the trial court for approval on April 23, 2024.

{¶6} On May 13, 2024, the trial court approved the same. Mr. Porter’s balance

of $12,925.55 was reduced to $8,214.34; ACMC agreed to an additional reduction for a

Case No. 2024-A-0067 total debt of $4,654, plus interest at eight percent. Mr. Porter agreed to make timely

payments of $150 per month. The consent judgment entry provided that the failure to

make timely payments would result in execution on the outstanding balance of the

judgment.

{¶7} Later, both Ms. Porter and ACMC filed motions for summary judgment. Ms.

Porter claimed that any attempt to seek contingent liability against her if Mr. Porter failed

to pay was not a justiciable issue. Ms. Porter additionally maintained that ACMC’s debt

was extinguished and there was no remaining controversy before the court. She further

argued that ACMC does not have a claim against her under R.C. 3103.03(A) because

Mr. Porter has the ability to pay the debt.

{¶8} ACMC claimed that a relevant dispute remained whether Ms. Porter is liable

on any remaining debt if Mr. Porter is unable to pay. It maintained that the claim for

medical debt owed by Mr. Porter, or contingently alleged against Mr. Porter, is subject to

a set statute of limitations. According to ACMC, if it is not allowed to obtain a contingent-

liability judgment against Ms. Porter, but Mr. Porter ceases to pay prior to satisfying the

debt, ACMC would be precluded from seeking judgment against Ms. Porter because the

applicable statute of limitations will have passed. ACMC maintained that a spouse’s

inability to pay can arise after judgment obtained against the spouse debtor. Accordingly,

ACMC asserted a case in controversy existed between the remaining parties.

{¶9} Both parties duly opposed the respective motions.

{¶10} Upon consideration, the trial court agreed with Ms. Porter. In its judgment

entry awarding her summary judgment, the court observed:

In this matter, ACMC has settled the debt that [Mr. Porter] owes to it. The Terms of the claim resolution between ACMC 3

Case No. 2024-A-0067 and [Mr. Porter] are set forth in the Judgment Entry issued on May 13, 2024. This settlement resolves ACMC’s claim for the medical debt. ACMC’s claim against [Ms. Porter] is premised upon a situation where [Mr. Porter] breaches the settlement agreement and [Ms. Porter] becomes liable for the remainder of the debt pursuant to the necessaries statute[, i.e., R.C. 3103.03]. [Mr. Porter] has not yet breached the agreement. Therefore, ACMC’s controversy with [Ms. Porter] is a hypothetical. Since the controversy is “merely possible,” it is not an actual, justiciable matter.

{¶11} ACMC appealed the judgment and assigns the following as error:

{¶12} “The trial court erred when it determined that the plaintiff creditor was not

entitled to a judgment with contingent liability against the non-debtor spouse even though

the statute of limitations on the contract debt was expiring prior to full payment when a

similarly situated creditor well within the statute of limitations could institute suit against

the non-debtor spouse.”

Pursuant to Civ.R. 56, summary judgment is appropriate when (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 nonmoving party, said party being entitled to have the evidence construed most strongly in his favor.

(Citation omitted.) Zivich v. Mentor Soccer Club, 82 Ohio St.3d 367, 369-70, 1998-Ohio-

389.

{¶13} ACMC generally argues that the trial court’s judgment constitutes a denial

of its statutory and/or equal protection right to pursue a non-debtor spouse for payment

which otherwise exists if the debtor spouse becomes uncollectable or unable to pay within

the relevant statute of limitations.

{¶14} R.C. 3103.03(A) provides, in relevant part: “Each married person must

support the person’s self and spouse out of the person’s property or by the person’s labor. 4

Case No. 2024-A-0067 If a married person is unable to do so, the spouse of the married person must assist in

the support so far as the spouse is able.” (Emphasis added.)

{¶15} The foregoing provision originates from “coverture” wherein “a married

woman’s legal identity merged with her husband’s,” thus prohibiting her from owning

property, entering into contracts, or receiving credit. Embassy Healthcare v. Bell, 2018-

Ohio-4912, ¶ 4. Given these “legal disabilities,” courts developed the common-law

“necessaries doctrine” to “encourage[] third parties to provide essential items and

services to neglected wives.” (Citations omitted.) Id. So, under the common law, “a

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Kramer v. Time Warner Inc
937 F.2d 767 (Second Circuit, 1991)
Jersey Shore Medical Center-Fitkin Hospital v. Estate of Baum
417 A.2d 1003 (Supreme Court of New Jersey, 1980)
Bartrom v. Adjustment Bureau, Inc.
618 N.E.2d 1 (Indiana Supreme Court, 1993)
Hickory Creek at Connersville v. Estate of Otto K. Combs
992 N.E.2d 209 (Indiana Court of Appeals, 2013)
Royal Indemnity Co. v. Baker Protective Services, Inc.
515 N.E.2d 5 (Ohio Court of Appeals, 1986)
Travis v. Public Utilities Commission
175 N.E. 586 (Ohio Supreme Court, 1931)
Pollard v. Elber
2018 Ohio 4538 (Ohio Court of Appeals, 2018)
In re Adoption of L.S.
2020 Ohio 224 (Ohio Court of Appeals, 2020)
Rector v. Dorsey
2021 Ohio 2675 (Ohio Court of Appeals, 2021)
Fortner v. Thomas
257 N.E.2d 371 (Ohio Supreme Court, 1970)
Pack v. City of Cleveland
438 N.E.2d 434 (Ohio Supreme Court, 1982)
Ohio State University Hospital v. Kinkaid
549 N.E.2d 517 (Ohio Supreme Court, 1990)
Industrial Risk Insurers v. Lorenz Equipment Co.
69 Ohio St. 3d 576 (Ohio Supreme Court, 1994)
National Distillers & Chemical Corp. v. Limbach
643 N.E.2d 101 (Ohio Supreme Court, 1994)
State ex rel. Barclays Bank PLC v. Court of Common Pleas
660 N.E.2d 458 (Ohio Supreme Court, 1996)
State ex rel. Elyria Foundry Co. v. Industrial Commission
694 N.E.2d 459 (Ohio Supreme Court, 1998)
Zivich v. Mentor Soccer Club, Inc.
696 N.E.2d 201 (Ohio Supreme Court, 1998)
Cheshire Medical Center v. Holbrook
663 A.2d 1344 (Supreme Court of New Hampshire, 1995)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 803, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ashtabula-cty-med-ctr-v-porter-ohioctapp-2025.