Donaldson v. Ohio Dept. of Rehab. & Corr.

2024 Ohio 6110
CourtOhio Court of Appeals
DecidedDecember 31, 2024
Docket24AP-425
StatusPublished
Cited by3 cases

This text of 2024 Ohio 6110 (Donaldson v. Ohio Dept. of Rehab. & Corr.) 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
Donaldson v. Ohio Dept. of Rehab. & Corr., 2024 Ohio 6110 (Ohio Ct. App. 2024).

Opinion

[Cite as Donaldson v. Ohio Dept. of Rehab. & Corr., 2024-Ohio-6110.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

Ora J. Donaldson, Jr., :

Plaintiff-Appellant, : No. 24AP-425 (Ct. of Cl. No. 2023-00371JD) v. : (ACCELERATED CALENDAR) Ohio Department of Rehabilitation and : Correction, : Defendant-Appellee. :

D E C I S I O N

Rendered on December 31, 2024

On brief: Ora J. Donaldson, Jr., pro se.

On brief: Dave Yost, Attorney General, Maggie Shaver, and Charles R. Janes, for appellee.

APPEAL from the Court of Claims of Ohio MENTEL, P.J. {¶ 1} Plaintiff-appellant, Ora J. Donaldson, Jr., appeals from a June 18, 2024 decision granting the motion for summary judgment of defendant-appellee, Ohio Department of Rehabilitation and Correction (“ODRC”). For the reasons that follow, we affirm. I. FACTS AND PROCEDURAL HISTORY {¶ 2} On April 29, 2022, Donaldson, an inmate at the Correctional Reception Center (“CRC”), sustained injuries “while * * * awaiting transfer to the plaintiff’s parent institution.” (Compl. at 1.) According to Donaldson, he suffered injuries from an “improperly cared for and improperly maintained, and broken prison issued equipment i.e. a prison issued bed frame, which collapsed and has caused the plaintiff sever[e] personal injury.” (Compl. at 1.) Donaldson alleged that ODRC was negligent and breached its duty No. 24AP-425 2

of care when the “bed frame that the plaintiff was laying in collapsed.” (Compl. at 3.) Donaldson contends that ODRC staff was aware of the faulty bed frame as they would conduct “shake downs” and “separate these bedframes by breaking them apart as part of the cell shake downs sometimes as part of the inmates punishment, while conducting these shake downs causing the pins that connect the bed frame to the sleeping platform to become broken and missing which in turn cause a type of pendulum effect that then caused the frame to collapse in on itself.” (Sic. passim.) (Compl. at 3.) On May 22, 2023, Donaldson filed a complaint asserting a negligence claim against ODRC. On July 5, 2023, ODRC filed an answer denying all allegations in the complaint. {¶ 3} On May 10, 2024, ODRC filed a motion for summary judgment under Civ.R. 56(C). ODRC submitted affidavits from Corrections Specialist Madeline Jackson and Corrections Officer Dustie Carner with its motion for summary judgment. In both affidavits, the officers averred that Donaldson never reported or raised concerns with the bedframe until after the incident. (Carner Aff. at ¶ 7; Jackson Aff. at ¶ 10.) “Neither Mr. Donaldson nor any other incarcerated person personally notified any employees or agents of [O]DRC that there was a potential safety issue or problem with the bed frame in cell R2- 1106 before the April 29th incident.” (Jackson Aff. at ¶ 11.) Jackson also provided that the rounds of the unit or searches of the cell did not reveal any hazard, risk, or defect with Donaldson’s bedframe before the incident. (Jackson Aff. at ¶ 12.) On June 3, 2024, Donaldson filed an “Objection to Motion for Summary Judgment,” which the trial court construed as a memorandum in opposition to ODRC’s motion for summary judgment. A reply brief was filed on June 7, 2024. {¶ 4} On June 18, 2024, the trial court granted ODRC’s motion for summary judgment finding that there was no reasonable dispute of material fact in this case and ODRC was entitled to judgment as a matter of law. The trial court explained that ODRC’s motion and attached affidavits satisfied its initial burden to demonstrate that there was no reasonable dispute of fact that it had no prior notice of any hazard or defect with the bedframe. The trial court found that Donaldson failed to meet his reciprocal burden by No. 24AP-425 3

setting forth specific facts, through an affidavit or other permissible evidence pursuant to Civ.R. 56(E), showing that there was a genuine dispute for trial. {¶ 5} Donaldson filed a timely appeal. II. ASSIGNMENTS OF ERROR {¶ 6} Appellant assigns the following as trial court error: [I.] The Court of Claims erred in granting the Defendants motion for summary judgment under civil rule 56 (c) violating the Plaintiffs 6th and 14th constitutional right to due process. [II.] The Court of Claims erred by failing to accept, and hear, Plaintiffs opposition to the defendant’s motion for summary judgement. [III.] The Court of Claims erred in granting the Defendants motion for summary judgement by violating the Plaintiffs constitutional rights of prisoners 15-8-1. [IV.] The Court of Claims erred by failing to compel the defendants to provide the Plaintiff with discovery after the Plaintiffs repeatedly requested discovery in a timely manner. [V.] the Court of Claims erred in holding the pro se Plaintiff to the same standards as a licensed practicing attorney. [VI.] The Court of Claims erred by granting summary judgement under civil rule 56 (c) to the Defendants. [VII.] The Court of Claims erred in accepting the self-serving affidavits of the Defendants witnesses without providing any documented as to any proof that any security searches or safety inspection was conducted unit R 2 cell 1106 which is ODRC policy to document any and all cell search and inspection. (Sic passim.) III. LEGAL ANALYSIS A. App.R. 16 {¶ 7} Preliminarily, we note that Donaldson’s brief fails to comply with App.R. 16. Pursuant to App.R. 16(A)(7), an appellant must include in his brief “[a]n argument containing the contentions of the appellant with respect to each assignment of error presented for review and the reasons in support of the contentions, with citations to the authorities, statutes, and parts of the record on which appellant relies.” Here, Donaldson has failed to separately argue each assignment of error as well as cite to parts of the record which he relies. “While it is within this court’s discretion to address assignments of error No. 24AP-425 4

together, a party does not have this choice and is required to argue each assignment of error separately in its brief.” Jabr v. Burger King, 10th Dist. No. 21AP-463, 2022-Ohio-773, ¶ 11, citing Fiorilli Constr., Inc. v. A. Bonamase Contracting, Inc., 8th Dist. No. 94719, 2011- Ohio-107, ¶ 30. In the interests of justice, however, we will address Donaldson’s assignments of error as best we can discern. B. Appellant’s Fifth Assignment of Error {¶ 8} For ease of discussion, we will address Donaldson’s arguments out of order. In Donaldson’s fifth assignment of error, he argues that the trial court erred by holding him to the same standard as a licensed attorney. This argument is without merit. {¶ 9} The Supreme Court of Ohio has declared that “ ‘pro se litigants * * * must follow the same procedures as litigants represented by counsel.’ ” State ex rel. Neil v. French, 153 Ohio St.3d 271, 2018-Ohio-2692, ¶ 10, quoting State ex rel. Gessner v. Vore, 123 Ohio St.3d 96, 2009-Ohio-4150, ¶ 5; see also State ex rel. Fuller v. Mengel, 100 Ohio St.3d 352, 2003-Ohio-6448, ¶ 10, quoting Sabouri v. Ohio Dept. of Job & Family Servs., 145 Ohio App. 3d 651, 654 (10th Dist.2001) (“ ‘It is well-established that pro se litigants are presumed to have knowledge of the law and legal procedures and that they are held to the same standard as litigants who are represented by counsel.’ ”). In all civil matters, the same rules and standards apply to pro se litigants as those parties that are represented by counsel. Habtemariam-Brown v. Christensen, 10th Dist. No. 23AP-517, 2024-Ohio-4464, ¶ 13, citing Fields v. Stange, 10th Dist. No. 03AP-48, 2004-Ohio-1134, ¶ 7, citing Fuller at ¶ 10. Donaldson’s fifth assignment of error is overruled. C.

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Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 6110, Counsel Stack Legal Research, https://law.counselstack.com/opinion/donaldson-v-ohio-dept-of-rehab-corr-ohioctapp-2024.