Crenshaw v. Mooningham

2024 Ohio 1470
CourtOhio Court of Appeals
DecidedApril 18, 2024
Docket112835
StatusPublished

This text of 2024 Ohio 1470 (Crenshaw v. Mooningham) 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
Crenshaw v. Mooningham, 2024 Ohio 1470 (Ohio Ct. App. 2024).

Opinion

[Cite as Crenshaw v. Mooningham, 2024-Ohio-1470.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

MARIAH CRENSHAW, :

Plaintiff-Appellant, : No. 112835 v. :

CHELSEY MOONINGHAM, :

Defendant-Appellee. :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED RELEASED AND JOURNALIZED: April 18, 2024

Civil Appeal from the Cuyahoga County Court of Common Pleas Case No. CV-21-956163

Appearances:

Mariah Crenshaw, pro se.

Edwin V. Hargate III, for appellee.

FRANK DANIEL CELEBREZZE, III, J.:

Appellant Mariah Crenshaw (“Crenshaw”) challenges the judgment of

the Cuyahoga County Court of Common Pleas granting summary judgment in favor

of appellee Chelsea Mooningham (“Mooningham”) on Crenshaw’s claims for

defamation, intentional infliction of emotional distress, telephone harassment, and spoliation of evidence. After a thorough review of the applicable law and facts, we

affirm the judgment of the trial court.

I. Factual and Procedural History

This matter arises from statements made by Mooningham in social

media posts that Crenshaw alleges were defamatory to her, intentionally caused her

emotional distress, and constituted telephone harassment. Crenshaw filed suit

against Mooningham, and the parties engaged in discovery. Crenshaw later moved

the court to amend her complaint to include a claim for spoliation of evidence, which

was granted by the trial court, and Mooningham answered.

Both parties filed motions for summary judgment. The court denied

Crenshaw’s motion and granted Mooningham’s, finding that no genuine issues of

material fact remained and that Mooningham was entitled to judgment as a matter

of law.

Crenshaw then filed the instant appeal, raising one assignment of error

for our review:

The trial court erred and abused its discretion in granting a motion for summary judgment in violation of discovery civil rules, Civ.R. 56 requirements and evidentiary rules without having the ability to review all social media posts.

II. Law and Analysis

In her sole assignment of error, Crenshaw contends that she properly

identified the “multiple issues and violations” in her complaint and brief opposing

the motion for summary judgment that the trial court failed to consider. She maintains that she presented to the trial court social media posts along with her

affidavit under Civ.R. 56. She further asserts that an evidentiary conflict exists

between Mooningham’s discovery responses and her summary judgment motion,

which raises a genuine issue of material fact.

We review an appeal from summary judgment under a de novo

standard of review. Grafton v. Ohio Edison Co., 77 Ohio St.3d 102, 105, 671 N.E.2d

241 (1996); Zemcik v. LaPine Truck Sales & Equip. Co., 124 Ohio App.3d 581, 585,

706 N.E.2d 860 (8th Dist.1998). In Zivich v. Mentor Soccer Club, 82 Ohio St.3d

367, 369-370, 696 N.E.2d 201 (1998), the Supreme Court of Ohio set forth the

appropriate test as follows:

Pursuant to Civ.R. 56, summary judgment is appropriate when (1) there is no genuine issue of material fact, (2) the moving party is entitled to judgment as a matter of law, and (3) reasonable minds can come to but one conclusion and that conclusion is adverse to the nonmoving party, said party being entitled to have the evidence construed most strongly in his favor. Horton v. Harwick Chem. Corp., 73 Ohio St.3d 679, 653 N.E.2d 1196 [(1995)], paragraph three of the syllabus. The party moving for summary judgment bears the burden of showing that there is no genuine issue of material fact and that it is entitled to judgment as a matter of law. Dresher v. Burt, 75 Ohio St.3d 280, 292-293, 662 N.E.2d 264 [(1996)].

Once the moving party satisfies its burden, the nonmoving party “may

not rest upon the mere allegations or denials of the party’s pleadings, but the party’s

response, by affidavit or as otherwise provided in this rule, must set forth specific

facts showing that there is a genuine issue for trial.” Civ.R. 56(E); Mootispaw v.

Eckstein, 76 Ohio St.3d 383, 385, 667 N.E.2d 1197 (1996). Doubts must be resolved in favor of the nonmoving party. Murphy v. Reynoldsburg, 65 Ohio St.3d 356, 358-

359, 604 N.E.2d 138 (1992).

Crenshaw alleged in her amended complaint that Mooningham

“posted numerous slanderous, libelous, and defaming statements on social media

multiple times a day with intent to harass, annoy, and embarass [sic] the Plaintiff in

violation of R[.]C[.] 2739.01.” Crenshaw stated that Mooningham posted

Crenshaw’s court cases, home address, and financial information on social media to

harass, bully, and humiliate Crenshaw and has posted case information and court

dates, and called an unidentified member of Crenshaw’s family a “murderer.”

Crenshaw claimed that Mooningham’s actions have caused her extreme emotional

and psychological damages, affected her earning capacity and reputation, and

caused her to seek mental health counseling. Crenshaw sought damages in excess

of $400,000 plus “all court costs and fees associated with this action.”

Mooningham’s motion for summary judgment asserted that no

genuine issues of material fact remained for trial because (1) Crenshaw failed to

identify any libelous or slanderous statements; (2) Crenshaw cited the incorrect

legal elements for a telephone harassment claim; and (3) Crenshaw had no material

facts to support her claim for spoliation.

In response to Mooningham’s motion for summary judgment,

Crenshaw presented arguments relating to the admissibility of Mooningham’s

exhibits and noted that Mooningham did not deny that she was the author of the

posts or refuted the content. She further raised assertions relative to Mooningham’s counsel and the truthfulness of statements made in court filings and during phone

conferences with the court.

A. Defamation

Defamation, which includes both slander and libel, is the “publication

[of] a false statement ‘made with some degree of fault, reflecting injuriously on a

person’s reputation, or exposing a person to public hatred, contempt, ridicule,

shame or disgrace, or affecting a person adversely in his or her trade, business or

profession.’” Jackson v. Columbus, 117 Ohio St.3d 328, 2008-Ohio-1041, 883

N.E.2d 1060, ¶ 9, quoting A & B-Abell Elevator Co. v. Columbus/Cent. Ohio Bldg.

& Constr. Trades Council, 73 Ohio St.3d 1, 7, 651 N.E.2d 1283 (1995).

To prevail on a defamation claim, a plaintiff must prove that (1) a false

statement of fact, (2) about the plaintiff, (3) was published to a third party, (4) with

the requisite degree of fault on the part of the defendant, and (5) the statement was

either defamatory per se or was defamatory per quod, causing special harm to the

plaintiff. See, e.g., Geletka v. Radcliff, 8th Dist. Cuyahoga No. 110988, 2022-Ohio-

2497, ¶ 31; Lograsso v. Frey, 2014-Ohio-2054, 10 N.E.3d 1176, ¶ 13 (8th Dist.);

Garofolo v. Fairview Park, 8th Dist. Cuyahoga Nos. 92283 and 93021, 2009-Ohio-

6456, ¶ 17.

In Mooningham’s motion for summary judgment, she argued that

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2024 Ohio 1470, Counsel Stack Legal Research, https://law.counselstack.com/opinion/crenshaw-v-mooningham-ohioctapp-2024.