Buckeye Check Cashing Inc. v. Proctor, Unpublished Decision (6-15-1999)

CourtOhio Court of Appeals
DecidedJune 15, 1999
DocketNo. 98AP-1103
StatusUnpublished

This text of Buckeye Check Cashing Inc. v. Proctor, Unpublished Decision (6-15-1999) (Buckeye Check Cashing Inc. v. Proctor, Unpublished Decision (6-15-1999)) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law.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
Buckeye Check Cashing Inc. v. Proctor, Unpublished Decision (6-15-1999), (Ohio Ct. App. 1999).

Opinions

Buckeye Check Cashing, Inc., plaintiff-appellant, appeals a decision of the Franklin County Municipal Court. The trial court found that Toni L. Proctor, defendant-appellee, was liable to appellant for $287.50 plus legal interest and court costs. We affirm.

On December 5, 1997, appellant filed a complaint against appellee claiming that appellee "negotiated a check(s) * * * in the amount of $287.50 to [appellant] in exchange for cash. [Appellee's] bank has dishonored said check(s) and [appellee] has failed to make said check(s) good." Appellant claimed that pursuant to R.C. 2307.61, it was entitled to recover statutory damages in the amount of $862.50. In her answer to the complaint, appellee stated that she agreed with appellant that she was liable for "the returned check in the amount of $287.50 plus reasonable returned check costs." However, appellee also stated that she did not agree with the amount of damages appellant was claiming.

A trial was held and the trial court found that appellee was liable to appellant for "the sum of $287.50, plus legal interest thereon from the day such check was dishonored, and court costs." The court also found that "based upon the Court's interpretation of the requirements of § 2907.61 [sic], [appellant] proved it was entitled to judgment against [appellee] for the dishonored check which [appellee] wrote, but not for treble damages." Pursuant to Civ.R. 52, appellant requested findings of fact and conclusions of law from the trial court. On June 25, 1998, the court filed an entry that stated in part:

* * * [T]he pivotal issue for appellate review is whether § 2907.61 [sic], O.R.C., required [appellant], seeking treble damages, to file evidence of a written demand conforming to § 2907.61(A)(2)(a) and (C) [sic] O.R.C. This Court concluded the statute required such evidence, and (appellant] disagreed that such written demand evidence was required. [Emphasis sic.]

Appellant appeals the trial court's decision and presents the following assignment of error:

The Trial Court abused its discretion when it ruled that the notice requirement of R.C. Section 2307.61(A)(2)(a) applies whether or not a party attempting to collect treble damages for a bad check under the statute also seeks to recover the reasonable administrative costs, if any, the cost of maintaining the civil action, and reasonable attorney's fees.

Appellant argues in its assignment of error that the trial court abused its discretion because it found that appellant was required to comply with the notice requirements of R.C.2307.61(A)(2)(a) in order to recover treble damages. Appellant contends that it could recover treble damages without giving appellant a thirty-day notice before filing the complaint. We disagree.

R.C. 2307.61 permits property owners to seek prescribed compensatory or liquidated damages in the event of theft.City of Columbus v. Bednarz (Jan. 24, 1995), Franklin App. No. 94APC06-890, unreported (1995 Opinions 155, 157). R.C. 2307.61 states in part:

(A) If a property owner brings a civil action pursuant to division (A) of section 2307.60 of the Revised Code to recover damages from any person who willfully damages the owner's property or who commits a theft offense, as defined in section 2913.01 of the Revised Code, involving the owner's property, the property owner may recover as follows:

(1) In the civil action, the property owner may elect to recover moneys as described in division (A)(1)(a) or (b) of this section:

(a) Compensatory damages that may include, but are not limited to, the value of the property and liquidated damages in whichever of the following amounts applies:

(i) Fifty dollars, if the value of the property was fifty dollars or less at the time it was willfully damaged or was the subject of a theft offense:

(ii) One hundred dollars, if the value of the property was more than fifty dollars, but not more than one hundred dollars, at the time it was willfully damaged or was the subject of a theft offense;

(iii) One hundred fifty dollars, if the value of the property was more than one hundred dollars at the time it was willfully damaged or was the subject of a theft offense.

(b) Liquidated damages in whichever of the following amounts is greater:

(i) Two hundred dollars;

(ii) Three times the value of the property at the time it was willfully damaged or was the subject of a theft offense, irrespective of whether the property is recovered by way of replevin or otherwise, is destroyed or otherwise damaged, is modified or otherwise altered, or is resalable at its full market price.

(2) In a civil action in which the value of the property that was willfully damaged or was the subject of a theft offense is less than five thousand dollars, the property owner may recover damages as described in division (A)(1)(a) or (b) of this section and additionally may recover the reasonable administrative costs, if any, of the property owner that were incurred in connection with actions taken pursuant to division (A)(2) of this section, the cost of maintaining the civil action, and reasonable attorney's fees, if all of the following apply:

(a) The property owner, at least thirty days prior to the filing of the civil action, serves a written demand for payment of moneys as described in division (A)(1)(a) of this section and the reasonable administrative costs, if any, of the property owner that have been incurred in connection with actions taken pursuant to division (A)(2) of this section, upon the person who willfully damaged the property or committed the theft offense.

(b) The demand conforms to the requirements of division (C) of this section and is sent by certified mail, return receipt requested.

(c) Either the person who willfully damaged the property or committed the theft offense does not make payment to the property owner of the amount specified in the demand within thirty days after the date of its service upon that person and does not enter into an agreement with the property owner during that thirty-day period for that payment or the person who willfully damaged the property or committed the theft offense enters into an agreement with the property owner during that thirty-day period for that payment but does not make that payment in accordance with the agreement.

(B) If a property owner who brings a civil action pursuant to division (A) of section 2307.60 of the Revised Code to recover damages for willful damage to property or for a theft offense attempts to collect the reasonable administrative costs, if any, of the property owner that have been incurred in connection with actions taken pursuant to division (A)(2) of this section, the cost of maintaining the civil action, and reasonable attorney's fees, under authority of that division and if the defendant prevails in the civil action, the defendant may recover from the property owner reasonable attorney's fees, the cost of defending the civil action, and any compensatory damages that may be proven.

(C) For purposes of division (A)(2) of this section, a written demand for payment shall include a conspicuous notice to the person upon whom the demand is to be served that indicates all of the following:

(1) the willful property damage or theft offense that the person allegedly committed;

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Buckeye Check Cashing Inc. v. Proctor, Unpublished Decision (6-15-1999), Counsel Stack Legal Research, https://law.counselstack.com/opinion/buckeye-check-cashing-inc-v-proctor-unpublished-decision-6-15-1999-ohioctapp-1999.