Ashtabula Metro. Hous. Auth. v. Alexander

2023 Ohio 4607
CourtOhio Court of Appeals
DecidedDecember 18, 2023
Docket2023-A-0037, 2023-A-0038
StatusPublished

This text of 2023 Ohio 4607 (Ashtabula Metro. Hous. Auth. v. Alexander) 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 Metro. Hous. Auth. v. Alexander, 2023 Ohio 4607 (Ohio Ct. App. 2023).

Opinion

[Cite as Ashtabula Metro. Hous. Auth. v. Alexander, 2023-Ohio-4607.]

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

ASHTABULA METROPOLITAN CASE NOS. 2023-A-0037 HOUSING AUTHORITY, 2023-A-0038

Plaintiff-Appellee, Civil Appeals from the Municipal Court - vs -

VIOLA ALEXANDER, Trial Court Nos. 2023 CVG 00198 2023 CVG 00290 Defendant-Appellant.

OPINION

Decided: December 18, 2023 Judgment: Reversed and remanded

Daniel J. Rudary, Brennan, Manna & Diamond, LLC, 75 East Market Street, Akron, OH 44308 (For Plaintiff-Appellee).

Luke S. Condon and Elizabeth A. Zak, The Legal Aid Society of Cleveland, 1223 West 6th Street, Cleveland, OH 44113 (For Defendant-Appellant).

JOHN J. EKLUND, P.J.

{¶1} Appellant, Viola Alexander, appeals the judgment of the Ashtabula

Municipal Court granting forcible entry and detainer in favor of appellee, the Ashtabula

Metropolitan Housing Authority. Appellant has raised four assignments of error arguing

the following: (1) the trial court’s decision to issue an eviction was not supported by the

manifest weight of the evidence; (2) the evidence did not support finding appellant

engaged in drug related criminal activity in violation of her tenancy; (3) the trial court erred

by finding appellee had not waived its right to evict appellant when appellee recertified appellant’s Section 8 federal subsidy following the alleged breach; and (4) the trial court

lacked subject matter jurisdiction over the action because appellee accepted appellant’s

rent payments after appellee initiated the forcible entry and detainer action.

{¶2} Having reviewed the record and the applicable caselaw, the trial court

issued its judgment entry overruling appellant’s objections to the magistrate’s decision

after only 11 days and without the benefit of reviewing the transcript, which appellant

subsequently filed within 30 days of her objections to the magistrate’s decision. Thus, the

trial court failed to afford appellant 30 days to file a transcript pursuant to Civ.R.

53(D)(3)(b)(iii) and consequently failed to conduct an independent review of the

magistrate’s decision in violation of Civ.R. 53(D)(4)(d).

{¶3} Therefore, we reverse the judgment of the Ashtabula Municipal Court and

remand for the trial court to conduct an independent review of the magistrate’s decision

pursuant to Civ.R. 53(D)(4)(d).

Substantive and Procedural History

{¶4} Appellant lives at a public housing complex owned by appellee. Appellee

is a public housing authority subject to federal regulations.

{¶5} On March 28, 2023, appellee filed a complaint for forcible entry and detainer

in the Ashtabula Municipal Court. Appellee claimed that appellant had engaged in illegal

drug activity in her unit based solely on a chemical swab test on appellant’s bathroom air

intake vent which indicated the presence of methamphetamine, but which neither the

magistrate nor any other Ohio court (so far as we have found) has declared reliable. The

court, through a magistrate, held hearings on May 1, 2023, and June 12, 2023.

Case Nos. 2023-A-0037, 2023-A-0038 {¶6} Appellant raised two legal issues at the May 1 hearing: first arguing that

appellee waived its right to evict appellant by recertifying appellant’s Section 8 federal

subsidy for her lease; and second that appellee waived its right to evict appellant by

accepting April’s rent payment after issuing the three-day notice. The magistrate

requested additional briefing on the issues raised during trial.

{¶7} On May 2, 2023, appellee filed a Civ.R. 41(A)(1)(a) voluntary dismissal.

{¶8} On May 3, 2023, appellee served a second three-day notice on appellant.

{¶9} On May 12, 2023, appellee filed a second forcible entry and detainer action

against appellant based on the March 8 inspection. On May 31, 2023, appellant filed a

motion to strike and motion to consolidate the cases, arguing that as a trial on the merits

had already been held, appellee did not have the authority to unilaterally dismiss.

{¶10} Accordingly, the magistrate consolidated the cases and held a hearing on

June 12 based on the issuance of the second three-day notice. After the June 12 hearing,

the magistrate found that appellant was in breach of her lease and ordered restitution to

the premises in favor of appellee.

{¶11} On June 26, 2023, appellant filed objections to the magistrate’s decision

and appellee opposed. On July 7, 2023, the trial court overruled appellant’s objections to

the magistrate’s decision. The court referred to an email from appellant’s trial counsel

requesting an audio recording of the proceedings. However, the court said that no

transcript had yet been filed.

{¶12} On July 10, 2023, appellant filed a copy of the transcript with the trial court

and filed a notice of appeal with this court.

Case Nos. 2023-A-0037, 2023-A-0038 Assignments of Error and Analysis

{¶13} Appellant’s assignments of error state:

{¶14} “[1.] The trial court erred when it found that Plaintiff/Appellee met its burden

of proof to sustain an eviction.”

{¶15} “[2.] The trial court erred when it found Defendant/Appellant breached her

lease by participating in drug-related criminal activity.”

{¶16} “[3.] The trial court erred in granting restitution of the premises to

Plaintiff/Appellee by finding Plaintiff/Appellee had not waived its right to evict

Defendant/Appellant when it recertified Defendant’s/Appellant’s federal subsidy for the

next year, following the alleged breach.”

{¶17} “[4.] The trial court erred in granting restitution of the premises to

Plaintiff/Appellee because the trial court lacked subject matter jurisdiction over the forcible

entry and detainer action, based on Plaintiff’s/Appellee’s acceptance of

Defendant’s/Appellant’s rent after Plaintiff/Appellee had served jurisdictional R.C.

1934.04 notice.”

{¶18} Appellee first argues, alternatively, that appellant failed to file the transcripts

of the May 1 and June 12 hearings and thus waived any challenges to the magistrate’s

factual findings, so that appellant’s first two assignments of error are “red herrings.” In her

reply brief, appellant argues that she complied with Civ.R. 53(D)(3)(b)(iii), which requires

a party to file a transcript to support an objection to a magistrate’s decision within 30 days.

Appellant notes that she filed timely objections to the magistrate’s decision and that the

trial court did not afford her 30 days to file the transcripts of the hearings. Instead, the trial

court adopted the magistrate’s decision without the benefit of the transcript 11 days after

Case Nos. 2023-A-0037, 2023-A-0038 appellant filed her objections. Appellant ultimately filed the transcript with the trial court

on July 10, 14 days after filing her objections.

{¶19} Appellee then contends that if the adequacy of its evidence is reviewed

under the law, it plainly sufficed to sustain the court’s finding appellant in breach and to

order eviction. Both parties devote much of their briefing to debating this issue, the

questions it raises and how they would have us resolve them. These questions present a

series of close calls of both law and fact, but we feel constrained not to render judgment

on them at this time. It is plain from the record that the trial court failed to afford appellant

30 days to file the transcripts of the magistrate’s hearing before overruling appellant’s

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Bluebook (online)
2023 Ohio 4607, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ashtabula-metro-hous-auth-v-alexander-ohioctapp-2023.