Batsche v. Batsche

2024 Ohio 1234, 239 N.E.3d 1088
CourtOhio Court of Appeals
DecidedApril 1, 2024
DocketCA2023-08-051
StatusPublished
Cited by4 cases

This text of 2024 Ohio 1234 (Batsche v. Batsche) 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
Batsche v. Batsche, 2024 Ohio 1234, 239 N.E.3d 1088 (Ohio Ct. App. 2024).

Opinion

[Cite as Batsche v. Batsche, 2024-Ohio-1234.]

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO

CLERMONT COUNTY

THOMAS BATSCHE, SR., et al., :

Appellants, : CASE NO. CA2023-08-051

: OPINION - vs - 4/1/2024 :

CAROL VOGELE EGNOR BATSCHE, :

Appellee. :

CIVIL APPEAL FROM CLERMONT COUNTY COURT OF COMMON PLEAS PROBATE DIVISION Case No. 2021CV00327

Dinsmore & Shohl, LLP, and Sarah B. Cameron, for appellants.

Becker & Cade, and Dennis A. Becker, for appellee.

S. POWELL, P.J.

{¶ 1} Plaintiff-Appellants, Thomas and Jesse Batsche, appeal the decision and

judgment entry of the Clermont County Court of Common Pleas, Probate Division,

denying their motion for judgment notwithstanding the verdict and for new trial. Jesse

Batsche is the next of kin of the estate of Kimberly Batsche, an original plaintiff to this

action. Thomas and Kimberly Batsche are biological children of Ronald Batsche. For Clermont CA2023-08-051

readability purposes, the plaintiffs shall be referred to solely as "Thomas." Defendant-

Appellee, Carol Batsche, stepmother of Thomas, shall be referred to as "Carol."

General Background and Procedural Posture

{¶ 2} During their marriage, Ronald and Carol maintained money management

accounts with The Vanguard Group, Inc. Ronald also designated Carol as his power of

attorney in December of 2011. Ronald had Vanguard accounts that listed Thomas as a

beneficiary upon Ronald's death.

{¶ 3} The conflict of this case stems from two separate transactions initiated by

Carol from these accounts. The first was a $25,000 withdrawal on November 18, 2020

when Ronald was still alive but in Hospice care (the "November Withdrawal"). The

November Withdrawal went into an account under both Ronald's and Carol's names. The

second was a $50,000 withdrawal on January 5, 2021 (the "January Withdrawal") and

occurred after Ronald passed away on December 3, 2020. Ronald's health had been on

the decline since 2017.

{¶ 4} Thomas eventually learned about these transactions and filed suit. His

complaint alleged several causes of action relevant to this appeal: (1) tortious interference

with the expectancy of inheritance ("TIEI") as to the November Withdrawal; (2) civil theft

as to the January Withdrawal; and (3) conversion as to the January Withdrawal.

{¶ 5} During the ensuing litigation, Thomas filed a motion for summary judgment.

After the motion was denied, the case was tried to a jury. The jury found Carol not guilty

of TIEI as to the November Withdrawal but guilty of civil theft as to the January

Withdrawal. However, the jury awarded no damages to Thomas. While not an issue on

appeal, there is dispute about whether Carol returned the January Withdrawal to

Vanguard, which could have led to the jury's determination that Thomas was not damaged

by the civil theft.

-2- Clermont CA2023-08-051

{¶ 6} After trial, the court subsequently entered a judgment consistent with the

jury's verdict. In that judgment, the trial court also awarded Thomas no damages. The

trial later denied Thomas' motion for judgment notwithstanding the verdict and motion for

a new trial. Thomas now appeals.

{¶ 7} Further details will be discussed below.

{¶ 8} Assignment of Error No. 1:

{¶ 9} THE TRIAL COURT ERRED BY DENYING PLAINTIFFS' MOTION FOR

SUMMARY JUDGMENT.

A. Background

{¶ 10} As previously stated, Thomas filed for summary judgment as to his TIEI and

civil theft claims. In the alternative to his civil theft claim, Thomas asked for summary

judgment as to his conversion claim. The trial court denied the motion. As to his TIEI

claim, the trial court found that "[w]hile Carol had the opportunity to influence Ronald," as

she was his power of attorney, issues of material fact remained as to whether he "was

susceptible to influence, * * * [and] whether [Carol] actually exerted undue influence and

achieved the desired effect." As to Thomas' conversion claim, the trial court found:

The facts are undisputed that [Thomas] had an interest in the Vanguard funds as a result of [his] father's death. There is also no question here that the defendant intentionally exercised control over the fund in question by initiating the [January Withdrawal]. * * * [I]t is immaterial whether [Carol] thought she had the authority to withdraw the funds. This withdrawal interfered with the defendant's rights * * *.

Nonetheless, the trial court denied Thomas' motion for summary judgment, finding that

because conversion was an alternate claim for civil theft, the case should still proceed to

trial.

{¶ 11} Thomas argues on appeal that the trial court should have granted summary

judgment in his favor as to the TIEI claim as well as the conversion claim. Specifically,

-3- Clermont CA2023-08-051

Thomas argues that Carol failed to put forth evidence to overcome the legal presumption

that she violated her fiduciary duty to Ronald by initiating the November Withdrawal for

her benefit. Thus, Thomas contends that the trial court should have granted him summary

judgment as a matter of law. Additionally, Thomas argues that the trial court improperly

denied summary judgment as to his conversion claim after finding no issues of material

fact as to the claim.

B. Standard of Review

{¶ 12} A trial court may grant summary judgment when, "there is no genuine issue

of material fact remaining for trial, the moving party is entitled to judgment as a matter of

law, and reasonable minds can only come to a conclusion adverse to the nonmoving

party, construing the evidence most strongly in that party's favor." Total Quality Logistics,

L.L.C. v. JK & R Express, L.L.C., 12th Dist. Clermont, 2022-Ohio-3969, ¶ 17. Denial of

summary judgment is reviewed on a de novo basis, and appellate courts consider the

same standard as the trial court. Holtrey v. Wiedeman, 12th Dist. No. CA2023-01-011,

2023-Ohio-2440, ¶ 12.

{¶ 13} However, we have consistently held that denial of summary judgment based

on issues of material fact followed by a verdict in favor of the nonmoving party renders

the denial of summary judgment moot or harmless. South v. Browning, 12th Dist. Warren

No. CA2012-09-088, 2013-Ohio-1491, ¶ 27; Clarkwestern Dietrich Bldg. Systems, LLC v.

Certified Steel Stud Assn., Inc., 12th Dist. Butler No. CA2016-06-113, 2017-Ohio-2713, ¶

12; Camara v. Gill Dairy, LLC, 12th Dist. No. CA2022-10-023, 2023-Ohio-2339, 220

N.E.3d 257, ¶ 14. Errors in denying summary judgment that relate solely to legal

questions, however, are reviewable. Clarkwestern at ¶ 12.

C. Analysis

i. Tortious Interference with Expectancy of Inheritance

-4- Clermont CA2023-08-051

{¶ 14} To prove TIEI, a plaintiff must demonstrate five elements: (1) the existence

of an expected inheritance; (2) intentional interference with that expected inheritance by

the defendant; (3) the defendant's interference was tortious in nature, including instances

of fraud, duress, or undue influence; (4) "a reasonable certainty that the expectancy of

inheritance would have been realized, but for the interference by the defendant;" and (5)

damages resulting from the interference. Firestone v. Galbreath, 67 Ohio St.3d 87, 88

(1993).

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Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 1234, 239 N.E.3d 1088, Counsel Stack Legal Research, https://law.counselstack.com/opinion/batsche-v-batsche-ohioctapp-2024.