Brick v. McCoun

2020 Ohio 4371
CourtOhio Court of Appeals
DecidedSeptember 9, 2020
Docket2020 AP 03 0007
StatusPublished

This text of 2020 Ohio 4371 (Brick v. McCoun) 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
Brick v. McCoun, 2020 Ohio 4371 (Ohio Ct. App. 2020).

Opinion

[Cite as Brick v. McCoun, 2020-Ohio-4371.]

COURT OF APPEALS TUSCARAWAS COUNTY, OHIO FIFTH APPELLATE DISTRICT

DANIEL BRICK : JUDGES: : : Hon. W. Scott Gwin, P.J. Plaintiff-Appellant : Hon. Patricia A. Delaney, J. : Hon. Earle E. Wise, Jr., J. -vs- : : Case No. 2020 AP 03 0007 : HEATHER MCCOUN : : : Defendant-Appellee : OPINION

CHARACTER OF PROCEEDING: Appeal from the Tuscarawas County Court of Common Pleas, Juvenile Division, Case No. 2020 CC 00002

JUDGMENT: AFFIRMED

DATE OF JUDGMENT ENTRY: September 9, 2020

APPEARANCES:

For Plaintiff-Appellant: For Defendant-Appellee:

DANN GUINN DAVID HIPP P.O. Box 804 300 East High Ave. New Philadelphia, OH 44663 P.O. Box 90 New Philadelphia, OH 44663 Tuscarawas County, Case No. 2020 AP 03 0007 2

Delaney, J.

{¶1} Plaintiff-Appellant Daniel Brick appeals the March 2, 2020 judgment entry

of the Tuscarawas County Court of Common Pleas, Juvenile Division.

FACTS AND PROCEDURAL HISTORY

{¶2} Plaintiff-Appellant Daniel Brick (“Father”) and Defendant-Appellee Heather

McCoun (“Mother”) are the parents on G.B., born on November 17, 2019. On January 6,

2020, Attorney Dan Guinn filed on behalf of Father a Motion for Allocation of Parental

Rights and Responsibilities in regards to the custody of G.B. Mother filed an answer to

the complaint with a Motion for Disqualification of Attorney Guinn.

{¶3} In her motion for disqualification, Mother claimed Attorney Guinn had a

conflict of interest. Mother stated in her attached affidavit that on October 30, 2019, she

consulted with Attorney Guinn concerning the impending birth of G.B. There was no fee

for the initial consultation with Attorney Guinn. Mother stated she discussed with Attorney

Guinn “specific details concerning my relationship with [Father], his behavior, his ability

to care for his own children, and my concerns as to what [Father] would do after the birth

of our child.” Mother further stated she expected the information she provided to Attorney

Guinn would be confidential.

{¶4} On February 5, 2020, Mother filed a supplement to her motion to disqualify

that included Maternal Grandmother’s affidavit. Maternal Grandmother also attended

Mother’s initial consultation with Attorney Guinn. Mother requested an evidentiary

hearing.

{¶5} Father responded to the motion to disqualify on February 11, 2020. In the

response, Attorney Guinn stated that Mother did not provide any confidential information Tuscarawas County, Case No. 2020 AP 03 0007 3

during the initial consultation. He claimed the initial consultation was approximately ten

minutes in length and they did not discuss any confidential details. Mother’s meeting was

so perfunctory that when he met with Father, Attorney Guinn did not recall meeting with

Mother. Attorney Guinn challenged Maternal Grandmother’s affidavit as being

contradictory to Mother’s affidavit on specific details of the consultation. For example,

Mother did not state in her affidavit how she learned of Attorney Guinn but said she knew

he offered a free initial consultation and provided a copy of his Facebook page.

Conversely, Maternal Grandmother claimed she was referred to Attorney Guinn by a

friend. Attorney Guinn did not attach an affidavit to the response, but contended an

evidentiary hearing was not necessary.

{¶6} On February 14, 2020, the magistrate conducted a non-oral hearing of the

motion to disqualify Attorney Guinn. The magistrate granted the motion to disqualify.

{¶7} Father filed objections to the Magistrate’s Decision. On March 2, 2020, the

trial court overruled the objections and adopted the Magistrate’s Decision.

{¶8} It is from this judgment that Father now appeals.

ASSIGNMENTS OF ERROR

{¶9} Father raises one Assignment of Error:

{¶10} “THE COURT ERRED IN DISQUALIFYING COUNSEL BASED ON A

CONFLICT OF INTEREST AS COUNSEL DID NOT OBTAIN ANY CONFIDENTIAL

INFORMATION FROM THE OPPOSING PARTY.” Tuscarawas County, Case No. 2020 AP 03 0007 4

ANALYSIS

{¶11} Father argues in his sole Assignment of Error that the trial court abused its

discretion when it granted Mother’s motion to disqualify Attorney Guinn because Mother

did not give Attorney Guinn confidential information. We disagree.

Disqualification

{¶12} A trial court's disqualification of counsel is an order that affects a substantial

right and is final and appealable under R.C. 2505.02. Royer v. Dillow, 5th Dist. Richland

No. 13 CA 71, 2014-Ohio-53, 2014 WL 98601, ¶ 8 citing Ross v. Ross, 94 Ohio App.3d

123, 129, 640 N.E.2d 265 (8th Dist.1994). A determination to disqualify or not disqualify

counsel is within the sound discretion of the trial court. Id. citing Sarbey v. National City

Bank, Akron, 66 Ohio App.3d 18, 583 N.E.2d 392 (9th Dist.1990). To find an abuse of

discretion, we must determine that the trial court's decision was unreasonable, arbitrary,

or unconscionable and not merely an error of law or judgment. Blakemore v. Blakemore,

5 Ohio St.3d 217, 450 N.E.2d 1140 (1983). Disqualification “is a drastic measure which

should not be imposed unless absolutely necessary.” Waliszewski v. Caravona Builders,

Inc., 127 Ohio App.3d 429, 433, 713 N.E.2d 65 (9th Dist.1998) (additional citations and

internal quotations omitted).

The Dana Test

{¶13} When ruling on a motion for disqualification, a trial court must consider the

following three-part test, and determine whether:

(1) A past attorney-client relationship existed between the party seeking

disqualification and the attorney it seeks to disqualify; Tuscarawas County, Case No. 2020 AP 03 0007 5

(2) the subject matter of those relationships was/is substantially related; and

(3) the attorney acquired confidential information from the party seeking

disqualification.

In re McCauley, 5th Dist. Stark No. 2011CA00272, 2012-Ohio-4709, 2012 WL 4831639,

¶¶ 44-45 quoting Phillips v. Haidet, 119 Ohio App.3d 322, 325, 695 N.E.2d 292 (3rd

Dist.1997) quoting Dana Corp. v. Blue Cross & Blue Shield Mut. of N. Ohio, 900 F.2d 882,

889 (C.A.6 1990). The three-pronged test is known as the “Dana test.”

{¶14} In his appeal, Father does not dispute the first and second prongs of the

three-part Dana test that (1) an attorney-client relationship existed between Mother and

Attorney Guinn and (2) the subject matter of the attorney-client relationships of Mother

and Father were substantially related to the custodial rights to G.B. Father’s sole

Assignment of Error contends the trial court erred as to the third prong of the Dana test

whether Attorney Guinn obtained confidential information from Mother.

Confidential Information

{¶15} The third prong of the Dana test requires the disqualification of an attorney

who acquired confidential information during a prior representation of the moving party.

Father argues that during his consultation with Mother, Attorney Guinn did not acquire

any confidential information from Mother. Father refers to Mother’s affidavit where she

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

Related

T. C. Theatre Corp. v. Warner Bros. Pictures, Inc.
113 F. Supp. 265 (S.D. New York, 1953)
Royer v. Dillow
2014 Ohio 53 (Ohio Court of Appeals, 2014)
In re McCauley
2012 Ohio 4709 (Ohio Court of Appeals, 2012)
Sarbey v. Natl. City Bank, Akron
583 N.E.2d 392 (Ohio Court of Appeals, 1990)
Ross v. Ross
640 N.E.2d 265 (Ohio Court of Appeals, 1994)
Luce v. Alcox
848 N.E.2d 552 (Ohio Court of Appeals, 2006)
Waliszewski v. Caravona Builders, Inc.
713 N.E.2d 65 (Ohio Court of Appeals, 1998)
Phillips v. Haidet
695 N.E.2d 292 (Ohio Court of Appeals, 1997)
In re E.M.J.
2017 Ohio 1090 (Ohio Court of Appeals, 2017)
Blakemore v. Blakemore
450 N.E.2d 1140 (Ohio Supreme Court, 1983)
Wynveen v. Corsaro
106 N.E.3d 130 (Court of Appeals of Ohio, Eighth District, Cuyahoga County, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
2020 Ohio 4371, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brick-v-mccoun-ohioctapp-2020.