Bevelacqua v. Tancak

2025 Ohio 217
CourtOhio Court of Appeals
DecidedJanuary 27, 2025
Docket24CA012126
StatusPublished

This text of 2025 Ohio 217 (Bevelacqua v. Tancak) 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
Bevelacqua v. Tancak, 2025 Ohio 217 (Ohio Ct. App. 2025).

Opinion

[Cite as Bevelacqua v. Tancak, 2025-Ohio-217.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF LORAIN )

JOHN BEVELACQUA, ETC. C.A. No. 24CA012126

Appellant/Cross-Appellee

v. APPEAL FROM JUDGMENT ENTERED IN THE JUSTIN D. TANCAK, et al. COURT OF COMMON PLEAS COUNTY OF LORAIN, OHIO Appellees/Cross-Appellants CASE No. 18-CV-196005

DECISION AND JOURNAL ENTRY

Dated: January 27, 2025

STEVENSON, Presiding Judge.

{¶1} Appellant John Bevelacqua appeals from the decisions of the Lorain County Court

of Common Pleas granting summary judgment in favor of Appellee/Cross-Appellant Deputy

Adam Shaw (“Deputy Shaw”), Appellee Lorain County Board of Commissioners (“Lorain

County”), and Appellee Columbia Township on the issue of proximate cause. Deputy Shaw cross-

appeals the trial court’s judgment denying his motion for summary judgment on immunity under

R.C. 2744.02(A)(6). On the issue of proximate cause, we conclude that reasonable minds could

differ as to whether Deputy Shaw was a proximate cause of the crash that claimed Ms.

Bevelacqua’s life. Accordingly, we reverse and remand the trial court’s judgment granting

summary judgment on the issue of proximate cause. We affirm the trial court’s judgment denying

Deputy Shaw’s motion for summary judgment on immunity under R.C. 2744.02(A)(6). 2

I.

Relevant Background

{¶2} This is not the first appeal filed in this matter. Mr. Bevelacqua appealed the trial

court’s decision granting summary judgment in favor of Lorain County, Columbia Township, and

Deputy Shaw in Bevelacqua v. Tancak, 2022-Ohio-4442 (9th Dist.) (“Bevelacqua I”). This Court

summarized the pertinent facts as:

Just after 2:30 a.m. on August 20, 2016, Sara Bevelacqua was killed when she was thrown from the back of a motorcycle. Its driver, Justin Tancak, was speeding when Lorain County Sheriff’s Deputy Adam Shaw spotted him and signaled for him to stop. A chase ensued, and Deputy Shaw pursued Mr. Tancak at speeds of almost 120 mph. Several minutes later, Deputy Shaw was directed to terminate his pursuit. He acknowledged the directive, reduced his speed, and deactivated his cruiser’s lights and sirens. Nevertheless, he continued to follow the motorcycle and drive well over the posted speed limit. He was still following the motorcycle when Mr. Tancak lost control and crashed near the eastbound ramp to State Route 20 from State Route 57. The crash resulted in minor injuries to Mr. Tancak and fatal injuries to Ms. Bevelacqua. Following a review of the incident, the Lorain County Sheriff’s Department terminated Deputy Shaw’s employment.1

Mr. Bevelacqua, individually and as administrator of his daughter’s estate, filed suit against Mr. Tancak, Mr. Tancak’s insurance company, the Lorain County Sheriff’s Department, Deputy Shaw, and unnamed John Does. Mr. Bevelacqua later dismissed the insurance company from the suit and sought leave to file an amended complaint. The purpose of the amendment was to substitute Lorain County as a defendant in place of the Sheriff’s Department and Columbia Township as a defendant in place of an unnamed John Doe. Mr. Bevelacqua requested the latter substitution because he learned Deputy Shaw was engaged in patrol duties for Columbia Township at the time of the crash due to an agreement between the township and Lorain County for the provision of additional law enforcement services. Over objection the trial court allowed Mr. Bevelacqua to file his amended complaint.

Mr. Bevelacqua’s amended complaint alleged (1) a negligence claim against Mr. Tancak; (2) a gross neglect claim against Lorain County, Columbia Township, and Deputy Shaw, (3) a negligent hiring, training, and retention claim against Lorain County and/or Columbia Township; (4) an intentional and/or negligent infliction of

1 Deputy Shaw’s employment was later reinstated because an arbitrator found that he had not been disciplined within the timeframe set forth by his employment contract and that his reinstatement would not offend public policy. 3

emotional distress claim against all named defendants; and (5) a wrongful death claim against all defendants. The amended complaint sought compensatory damages, burial and funeral expenses, costs, attorney fees, and punitive damages from all named defendants, jointly and severally. Each named defendant answered the amended complaint, and Deputy Shaw and Columbia Township cross-claimed Mr. Tancak for indemnification.

Lorain County, Columbia Township, and Deputy Shaw moved for summary judgment on various grounds, including statutory immunity. Mr. Bevelacqua filed briefs in opposition to each of their motions, and the three defendants filed replies. Upon review, the trial court awarded summary judgment to Lorain County, Columbia Township, and Deputy Shaw. Mr. Bevelacqua then filed a notice of voluntary dismissal with respect to his claims against Mr. Tancak, and the trial court dismissed those claims.

(Footnote in original.) Bevelacqua I at ¶ 2-5.

{¶3} Mr. Bevelacqua appealed the trial court’s decision awarding summary judgment to

Lorain County, Columbia Township, and Deputy Shaw in Bevelacqua I. He argued in his first

appeal that the trial court erred in ruling that Deputy Shaw was responding to an emergency call

and entitled to immunity under R.C. 2744.02; there was no question of fact as to the willful,

wanton, or reckless misconduct of Deputy Shaw; Mr. Tancak’s conduct was the sole proximate

cause of the motorcycle crash; and Lorain County was entitled to summary judgment on his

negligent retention claim. Id. at ¶ 7, 25, 33, 37. This Court affirmed in part and reversed in part

the trial court’s decision and remanded the matter for further proceedings. Id. at ¶ 42.

{¶4} This Court noted in Bevelacqua I that Mr. Bevelacqua’s argument that Deputy

Shaw was not responding to an emergency call and, therefore, not entitled to political subdivision

immunity was misplaced. Id. at ¶ 16. This argument was misplaced because “R.C. 2744.02(B)

only pertains to political subdivisions[]” and “R.C. 2744.03(A)(6) governs individual immunity

and does not require proof that an employee was responding to an emergency call.” Id. This Court

accordingly limited its review and concluded that the trial court erred when it granted summary

judgment to Lorain County and Columbia Township. Id. at ¶ 16, 24. The trial court erred because 4

“Mr. Bevelacqua set forth evidence of a triable issue regarding Lorain County and Columbia

Township’s ability to prove Deputy Shaw was responding to an emergency call, and therefore, to

avail themselves of the immunity protections set forth in R.C. 2744.02(B)(1)(1).” Id. at ¶ 24.

{¶5} This Court then concluded in Bevelacqua I that, based on the “determin[ation] [that]

genuine issues of material fact remain as to whether Deputy Shaw was responding to an emergency

call[,] . . . [a]ny opinion this Court offered on the issue of whether Deputy Shaw engaged in willful

or wanton misconduct would be purely advisory with respect to Lorain County and Columbia

Township.” Id. at ¶ 29. With respect to Deputy Shaw, this Court declined to address the evidence

against him because the trial court had not considered in the first instance the evidence within the

context of R.C. 2744.03(A)(6). Id. at ¶ 32.

{¶6} This Court next concluded in Bevelacqua I that, because the trial court applied the

incorrect law when determining whether Deputy Shaw is immune from suit, the issue of proximate

cause was premature, and we declined to address the merits of this argument. Id. at ¶ 33. We noted

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Bluebook (online)
2025 Ohio 217, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bevelacqua-v-tancak-ohioctapp-2025.