Dearth v. Fifth Third Bank

2013 Ohio 2686
CourtOhio Court of Appeals
DecidedJune 26, 2013
Docket12CA3335
StatusPublished

This text of 2013 Ohio 2686 (Dearth v. Fifth Third Bank) 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
Dearth v. Fifth Third Bank, 2013 Ohio 2686 (Ohio Ct. App. 2013).

Opinion

[Cite as Dearth v. Fifth Third Bank, 2013-Ohio-2686.]

IN THE COURT OF APPEALS OF OHIO FOURTH APPELLATE DISTRICT ROSS COUNTY

CHARLES E. DEARTH, : Case No. 12CA3335 DBA CANDLE SENSE, LLC, : : Plaintiff-Appellant, : : DECISION AND v. : JUDGMENT ENTRY : FIFTH THIRD BANK, : : RELEASED 6/26/13 Defendant-Appellee. : ______________________________________________________________________ APPEARANCES:

Joseph P. Sulzer, Chillicothe, Ohio, for appellant.

James E. Burke, Drew M. Micks, Keating Muething & Klekamp PLL, Cincinnati, Ohio, and James L. Mann, Mann & Preston, LLP, Chillicothe, Ohio, for appellee. ______________________________________________________________________ Harsha, J.

{¶1} Charles Dearth appeals an entry granting summary judgment to Fifth Third

Bank (Fifth Third) and initially contends that certain affidavits attached to the motion do

not comply with Civ.R. 56(E). Originally, Dearth contested his membership in a federal

class action lawsuit that was based on the same re-sequencing of debit card

transactions that is the subject of this case. However, the federal court subsequently

denied his petition to withdraw as a member of the class and Dearth conceded his

membership. Because the affidavits he complains of relate solely to his status as a

member of the class action in federal court, and he has conceded his membership in

that class, any irregularities in those affidavits are now irrelevant.

{¶2} He also argues that the fourth cause of action in his complaint is not

barred by the doctrine of res judicata because it is not a claim that could have been Ross App. No. 12CA3335 2

litigated in the class action suit. However, even if we assume that to be true, his claim

is subject to a release. As part of the settlement agreement in the class action, every

member released Fifth Third from any claims relating in any way to the re-sequencing of

debit card transactions and overdraft fees. And because his fourth cause of action

relates to the closure of his checking account due to overdraft fees from the re-

sequencing of Dearth’s debit card transactions, the trial court did not err by granting

summary judgment in favor of Fifth Third on the basis of release.

I. FACTS

{¶3} This action arises from a business checking account Charles Dearth

opened with Fifth Third Bank. In his amended complaint, Dearth alleged that Fifth Third

improperly re-sequenced transactions in his checking account in order to maximize

overdraft fees. Dearth alleged that Fifth Third would hold checking account transactions

until the end of the day and thereafter post the transactions from the largest dollar

amount to the smallest, regardless of when the charges were actually made. He also

alleged this practice maximized the number of overdraft fees Fifth Third could charge

him. In response Fifth Third filed an answer and motion to stay pending final approval

of a nationwide class action in federal court. It asserted that the class action was also

based on re-sequencing of debit card transactions and as a member Dearth would be

precluded from independently pursuing the claims in his complaint.

{¶4} After the court denied the motion, Fifth Third filed amended motions for

summary judgment based on the federal court’s approval of the class action settlement.

The trial court granted Fifth Third’s motion for summary judgment finding that Dearth

was a member in the class and therefore he released Fifth Third from any claims Ross App. No. 12CA3335 3

relating to the re-sequencing of debit card transactions. Dearth now appeals that

judgment.

II. ASSIGNMENT OF ERROR

{¶5} Dearth raises one assignment of error for our review:

1. THE TRIAL COURT’S GRANTING SUMMARY JUDGMENT FOR THE DEFENDANT-APPELLEE WAS AGAINST THE MANIFEST WEIGHT OF THE EVIDENCE.

III. LAW AND ANALYSIS

A. Affidavits Submitted In Support of Summary Judgment

{¶6} Initially Dearth argues that certain affidavits submitted by Fifth Third along

with its amended motion for summary judgment do not comply with Civ.R. 56(E)

because they did not include “the required documents that were allegedly mailed to

Appellant, the best evidence,” or “any verified copies or records actually maintained by

Appellee’s Affiant which demonstrates mailings, phone calls, etc., regarding the

Appellant.”

{¶7} However, we need not address the merits of Dearth’s argument because

the affidavits he complains of deal solely with his notification and membership in the

class action. In both affidavits the Claims Administrator discusses the initial post card

sent to Dearth notifying him of the pending class action and Dearth’s subsequent

request for additional information. Although initially Dearth denied that he was a

member of the class, on appeal Dearth concedes his membership in the class.

Presumably this is so because the United States District Court of the Northern District of

Illinois denied his petition to withdraw from the class and determined that Dearth

received timely notification of the class action. Thus, any affidavit concerning his Ross App. No. 12CA3335 4

notification and membership in the class was only relevant to an issue he now

concedes. Even if we assume it was error to consider the affidavits, their consideration

could not possibly be prejudicial in light of his concession.

B. Res Judicata

{¶8} The remainder of Dearth’s assignment of error involves the doctrine of res

judicata. Dearth argues that although Fifth Third’s motion for summary judgment

“centers on the issue of res judicata,” count four of his complaint is not barred by his

participation in the class action lawsuit because count four is not the type of claim he

could have litigated there. Dearth contends that “cause of action number four is not

based solely and strictly upon the ‘re-sequencing’ of debit card transactions,” but rather

“relates to the conduct of the Appellee’s agents and their malicious conduct[.]” 1

{¶9} We review the trial court's decision on a motion for summary judgment de

novo. Smith v. McBride, 130 Ohio St.3d 51, 2011-Ohio-4674, 955 N.E.2d 954, ¶ 12.

“Accordingly, we afford no deference to the trial court’s decision and independently

review the record to determine whether summary judgment is appropriate.” Snyder v.

Stevens, 4th Dist. No. 12CA3465, 2012-Ohio-4120, ¶ 11.

{¶10} Under Civ.R. 56(C), summary judgment is appropriate only if “‘(1) no

genuine issue of any material fact remains[;] (2) the moving party is entitled to judgment

as a matter of law[;] and (3) it appears from the evidence that reasonable minds can

come to but one conclusion, and construing the evidence most strongly in favor of the

nonmoving party, that conclusion is adverse to the party against whom the motion for

1 Dearth alleges three other causes of action in this complaint: (1) violations of the Ohio Consumer Sales Practice Act; (2) breach of contract; and (3) unjust enrichment. Dearth does not present any arguments on appeal concerning the other causes of action in his complaint. Likewise, we do not address them. Ross App. No. 12CA3335 5

summary judgment is made.’” DIRECTV, Inc. v. Levin, 128 Ohio St.3d 68, 2010-Ohio-

6279, 941 N.E.2d 1187, ¶ 15, quoting State ex rel. Duncan v. Mentor City Council, 105

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Related

DIRECTV, Inc. v. Levin
2010 Ohio 6279 (Ohio Supreme Court, 2010)
Smith v. McBride
2011 Ohio 4674 (Ohio Supreme Court, 2011)
Snyder v. Stevens
2012 Ohio 4120 (Ohio Court of Appeals, 2012)
Dresher v. Burt
662 N.E.2d 264 (Ohio Supreme Court, 1996)
State ex rel. Duncan v. City of Mentor City Council
826 N.E.2d 832 (Ohio Supreme Court, 2005)

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