Christoff v. Am. Airlines, Inc.

2024 Ohio 4810, 254 N.E.3d 238
CourtOhio Court of Appeals
DecidedOctober 4, 2024
Docket30161
StatusPublished

This text of 2024 Ohio 4810 (Christoff v. Am. Airlines, Inc.) 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
Christoff v. Am. Airlines, Inc., 2024 Ohio 4810, 254 N.E.3d 238 (Ohio Ct. App. 2024).

Opinion

[Cite as Christoff v. Am. Airlines, Inc., 2024-Ohio-4810.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT MONTGOMERY COUNTY

NICHOLAS P. CHRISTOFF : : Appellant : C.A. No. 30161 : v. : Trial Court Case No. 2023 CVI 4622 : AMERICAN AIRLINES, INC. : (Civil Appeal from Municipal Court) : Appellee : :

...........

OPINION

Rendered on October 4, 2024

NICHOLAS P. CHRISTOFF, Pro Se Appellant

AMANDA K. WAGER, Attorney for Appellee

.............

EPLEY, P.J.

{¶ 1} Plaintiff-Appellant Nicholas P. Christoff appeals from a judgment of the

Dayton Municipal Court, which overruled his objections to the magistrate’s decision on -2-

his claims and entered judgment in favor of Defendant-Appellee American Airlines, Inc.

For the following reasons, the trial court’s judgment will be affirmed.

I. Facts and Procedural History

{¶ 2} Christoff’s claims arose from American Airlines’ delay in delivering his

luggage to his final destination in Florida. According to Christoff, he and his wife

purchased tickets from American Airlines for travel from Dayton to Daytona Beach on

Saturday, June 17, 2023. They spent $140 to check their four bags. Due to mechanical

issues, their early afternoon flight from Dayton was delayed, and the airline informed them

that they would miss their connection in Charlotte. They initially were told that they had

been rebooked on a flight from Charlotte to Daytona Beach for the following morning and

would need to retrieve their bags in Charlotte. Once in Charlotte, however, American

Airlines rebooked them on a flight later that same day. The Christoffs believed their

luggage would be on this flight. When they arrived shortly after midnight, they learned

their luggage had been delayed.

{¶ 3} Over the next few days, Christoff made numerous phone calls to determine

the status of the luggage. Two of the bags arrived later on June 18. He drove from his

resort approximately 40 miles away to retrieve them from the airport. On June 19,

Christoff flew to Dayton to get the other two bags from the Dayton airport, where they

reportedly had been returned. There, Christoff learned that the bags had arrived at the

Dayton airport but had been redirected back to Daytona Beach. On June 20, Christoff

confirmed that the bags were being held at the Daytona Beach airport, and his family

members retrieved the luggage. Christoff returned to Florida on June 21. His Florida -3-

vacation concluded on June 24, 2023.

{¶ 4} On August 28, 2023, Christoff filed a small claims action against the chief

operating officer and chief executive officer of American Airlines. Two days later, he

added American Airlines as a defendant, and on September 11, 2023, he amended his

complaint to name American Airlines only. Christoff sought $5,000 for losses he incurred

due to American Airlines’ negligent performance.

{¶ 5} The matter proceeded to a bench trial on October 11, 2023. Christoff

submitted a binder with several exhibits; American Airlines submitted its “Conditions of

Carriage.” The next day, the magistrate issued a decision entering judgment in favor of

American Airlines at Christoff’s cost. Christoff timely objected but failed to submit a

transcript of the bench trial. On January 22, 2024, the trial court overruled the objections

on the ground that no transcript had been provided.

{¶ 6} Christoff appealed from the trial court’s judgment and requested the

preparation of a trial transcript. Montgomery C.A, No. 30067. The transcript was filed

in the appellate case on March 7, 2024. Soon after, however, we dismissed the appeal

for lack of a final appealable order. We indicated that the trial court had failed to

separately enter its own judgment setting forth the outcome of the dispute and the remedy

provided. Decision and Final Judgment Entry (Mar. 27, 2024).

{¶ 7} On April 30, 2024, the trial court issued a corrected judgment entry, adopting

the magistrate’s decision and entering judgment for American Airlines on Christoff’s claim

at his cost. Christoff appeals from the trial court’s judgment, raising six assignments of

error. They state: -4-

1. The trial court erroneously concluded that the American Airlines

Conditions of Carriage document (“Contract”) does not require American

Airlines to pay for lost, damaged, or delayed bags.

2. The trial court erred in failing to consider whether the American Airlines

Conditions of Carriage document (“Contract”) was unconscionable.

3. The trial court erred in failing to consider whether the Contract is

inconsistent with the US Department of Transportation Guidelines.

4. The trial court erred in failing to consider whether the Contract is

inconsistent with the Ohio Consumer Sales Practices Act (OCSPA).

5. The trial court (Dayton Municipal Court) erred in failing to review the

factual and legal basis for the Magistrate Judge’s Decision.

6. The trial court erred in not conducting, prior to issuing a ruling, any

meaningful review of the documentary evidence which Dr. Christoff

submitted in compliance with the “Notice to All Parties” form, filed by Dr.

Christoff on September 11, 2023.

II. Review of Trial Court’s Judgment

{¶ 8} As an initial matter, the magistrate’s decision was a general verdict, which

did not include findings of fact and conclusions of law. Such a decision is permitted

under Civ.R. 53(D)(3)(a)(ii). A request for findings of fact and conclusions of law must

be made before the entry of the magistrate’s decision or within seven days of the filing of

the decision. Id. Neither party made such a request.

{¶ 9} In addition, the Ohio Rules of Civil Procedure require a party to file written -5-

objections to a magistrate’s decision within 14 days of the filing of the decision. Civ.R.

53(D)(3)(b). Objections to factual findings must be supported by a transcript of all the

evidence submitted to the magistrate relevant to that finding or an affidavit of that

evidence if a transcript is not available. Civ.R. 53(D)(3)(b)(iii). The trial court may enter

judgment either during the 14-day period for filing objections or after the 14 days have

expired. Civ.R. 53(D)(4)(e)(i).

{¶ 10} Christoff filed timely objections on October 23, 2023. Accordingly, the trial

court was required to “undertake an independent review as to the objected matters to

ascertain that the magistrate has properly determined the factual issues and appropriately

applied the law.” Civ.R. 53(D)(4)(d),

{¶ 11} We note that the appellate record contains a trial transcript. However, the

trial transcript was prepared as part of Christoff’s first appeal (Case No. 30067), and we

see no indication that it was provided to the trial court at any time. Accordingly, the trial

transcript may not be considered in reviewing the trial court’s determination. See Geter

v. Geter, 2022-Ohio-2804, ¶ 26 (2d Dist.). Moreover, the parties’ exhibits, which were

available for the trial court’s review, may be considered only to the extent that an assigned

error may be resolved by reference to the exhibits alone and does not rely on trial

testimony for context or explanation. See id.; Huger v. Ashenafi, 2022-Ohio-492, ¶ 13

(2d Dist.).

{¶ 12} When the trial court’s judgment was made without the benefit of a transcript

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Related

Albritton v. White
2011 Ohio 3499 (Ohio Court of Appeals, 2011)
Wise v. Webb
2015 Ohio 4298 (Ohio Court of Appeals, 2015)
Huger v. Ashenafi
2022 Ohio 492 (Ohio Court of Appeals, 2022)
Geter v. Geter
2022 Ohio 2804 (Ohio Court of Appeals, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 4810, 254 N.E.3d 238, Counsel Stack Legal Research, https://law.counselstack.com/opinion/christoff-v-am-airlines-inc-ohioctapp-2024.