Doors On-Line v. Chandra

2023 Ohio 2018, 218 N.E.3d 226
CourtOhio Court of Appeals
DecidedJune 20, 2023
Docket17-22-11
StatusPublished
Cited by2 cases

This text of 2023 Ohio 2018 (Doors On-Line v. Chandra) 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
Doors On-Line v. Chandra, 2023 Ohio 2018, 218 N.E.3d 226 (Ohio Ct. App. 2023).

Opinion

[Cite as Doors On-Line v. Chandra, 2023-Ohio-2018.]

IN THE COURT OF APPEALS OF OHIO THIRD APPELLATE DISTRICT SHELBY COUNTY

DOORS ON-LINE INC.,

PLAINTIFF-APPELLEE, CASE NO. 17-22-11

v.

ROHIT CHANDRA, OPINION

DEFENDANT-APPELLANT.

Appeal from Sidney Municipal Court Trial Court No. 21CVF01181

Judgment Reversed and Cause Remanded

Date of Decision: June 20, 2023

APPEARANCES:

Jared B. Chamberlain for Appellant Case No. 17-22-11

ZIMMERMAN, J.

{¶1} Defendant-appellant, Rohit Chandra (“Chandra”), appeals the

September 26, 2022 judgment of the Sidney Municipal Court granting judgment in

favor of plaintiff-appellee, Doors On-Line, Inc. (“Doors On-Line”). For the reasons

that follow, we reverse.

{¶2} This case stems from Chandra’s, a resident of California, purchase of a

garage door from Doors On-Line. Doors On-Line, an Ohio corporation, “is an

online dealership for a manufacturer of a couple different lines of doors, a

nationwide dealership * * * .” (Sept. 20, 2022 Tr. at 12). Importantly, once a

purchase is completed, an out-of-state manufacturer, not Doors On-Line, schedules

the installation and ships the product. (See id. at 53).

{¶3} Here, Chandra initially purchased a garage door from Doors On-Line

on May 28, 2020. Significantly, because Chandra’s order “was a very customized

order [, it] had to [be] placed by phone.” (Id. at 15). As a result of Chandra’s order,

a “sight check by the installer” was scheduled for July 8, 2020 to “verify that

everything on the order [would] allow [the garage door] to be installed properly.”

(Id. at 16). (See also Plaintiff’s Ex. 2). However, because Chandra requested

“various changes that needed to be made to the order for the installer to complete

the work,” “a new order [was] placed on July 29, 2020 to incorporate the various

changes.” (Doc. No. 8). The garage door was installed in October 2020.

-2- Case No. 17-22-11

{¶4} Nevertheless, since Chandra was not satisfied with the installation of

the garage door, he filed a complaint with his credit-card company, which

“reversed” the charge. (See Sept. 20, 2022 Tr. at 39). As a result, Doors On-Line

did not receive payment for the garage door or installation costs. Consequently, on

November 1, 2021, Doors On-Line filed a small-claims complaint in the Sidney

Municipal Court seeking a judgment in the amount of $3,253.51, plus interest, from

Chandra.

{¶5} Chandra filed a motion to dismiss the complaint for a lack of personal

jurisdiction on February 11, 2022. On February 25, 2022, Doors On-Line filed a

memorandum in opposition to Chandra’s motion to dismiss. On May 23, 2022, the

trial court denied Chandra’s motion to dismiss without a hearing after concluding

that Doors On-Line satisfied its burden of proving that the trial court has personal

jurisdiction over Chandra since he had minimum contacts in Ohio. Specifically, the

trial court concluded that Doors-Online proved that Chandra had minimum contacts

in Ohio since Doors-Online “has [its] own website which [Chandra] used to contact

[Doors On-Line] for materials and services” and such “website * * * clearly

indicates [Doors On-Line’s] address in Russia, Shelby County, Ohio.” (Doc. No.

22).

{¶6} On August 5, 2022, Chandra filed his answer along with counterclaims

for breach of contract, a violation of Ohio’s consumer sales practices act, and design

-3- Case No. 17-22-11

defect. Doors On-Line filed its answer to Chandra’s counterclaims on August 19,

2022.

{¶7} The case proceeded to a bench trial on September 20, 2022. On

September 26, 2022, the trial court, again concluding that it had personal jurisdiction

over Chandra, awarded judgment in favor of Doors On-Line for $2,528.51—the cost

of only the garage door. (Doc. No. 34).

{¶8} Chandra filed his notice of appeal on October 24, 2022. He raises one

assignment of error for our review.

Assignment of Error

The Trial Court incorrectly determined it had personal jurisdiction over Defendant/Appellant, a California resident with no minimum contacts with Ohio.

{¶9} In his sole assignment of error, Chandra argues that the trial court erred

by concluding that it had personal jurisdiction over him because “[h]e has no

connection to Ohio, except a single online consumer purchase of a garage door from

an Ohio corporation known as Doors On-Line” that he “purchased * * * via Internet

transaction on May 28, 2020.” (Appellant’s Brief at 1). Specifically, Chandra

contends that he “had absolutely no reason – other than the obscurely located

address on the bottom/left corner of [Doors On-Line’s] website – to know he was

dealing with an Ohio corporation, and” his “single online purchase” “falls well short

-4- Case No. 17-22-11

of the threshold whereby Ohio could exercise personal jurisdiction over him.” (Id.

at 3). We agree.

Standard of Review

{¶10} “Whether personal jurisdiction exists is a question of law that we

review de novo.” Wedemeyer v. U.S.S. F.D.R (CV-42) Reunion Assoc., 3d Dist.

Allen No. 1-09-57, 2010-Ohio-1502, ¶ 37. “De novo review is independent and

without deference to the trial court’s determination.” ISHA, Inc. v. Risser, 3d Dist.

Allen No. 1-12-47, 2013-Ohio-2149, ¶ 25.

Analysis

{¶11} In this case, the trial court concluded that Doors On-Line presented

sufficient evidence for reasonable minds to conclude that it could exercise personal

jurisdiction over Chandra. Specifically, the trial court found that Doors On-Line

“has their [sic] own website which [Chandra] used to contact [Doors On-Line] for

materials and services” and that the website “clearly indicates [Doors On-Line’s]

address in Russia, Shelby County, Ohio.” (Doc. No. 22).

{¶12} However, Chandra argues that the trial court erred by concluding that

it had personal jurisdiction over him because its assertion of personal jurisdiction in

this case does not comport with the Due Process Clause of the Fourteenth

Amendment. In particular, Chandra contends that the trial court does not have

specific jurisdiction over him since he did not have “minimum contacts with the

-5- Case No. 17-22-11

State of Ohio * * * .” (Appellant’s Brief at 8). That is, Chandra argues that (1) he

“did not purposely avail himself of any privilege of doing business in the State of

Ohio where he merely used a publicly available website to complete a single

consumer transaction”; (2) “the cause of action does not arise from [his] activities

in Ohio”; and (3) he does not have a “substantial connection to Ohio * * * .”

(Emphasis sic.) (Id.).

{¶13} Doors On-Line did not respond to Chandra’s appellate argument

because it failed to file a brief in this case. Under such circumstances, App.R. 18(C)

provides that this court “may accept the appellant’s statement of the facts and issues

as correct and reverse the judgment if appellant’s brief reasonably appears to sustain

such action.” See Spinner v. Barger, 3d Dist. Shelby No. 17-16-27, 2017-Ohio-

1489, ¶ 5, fn. 1. After reviewing the record, and for the following reasons, we

conclude that Chandra’s brief reasonably appears to sustain a reversal.

{¶14} “This Court applies a two-part inquiry when deciding whether an out-

of-state defendant is subject to personal jurisdiction in an Ohio court.” Magnum

Asset Acquisition, LLC v. Green Energy Techs., LLC, 9th Dist.

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Cite This Page — Counsel Stack

Bluebook (online)
2023 Ohio 2018, 218 N.E.3d 226, Counsel Stack Legal Research, https://law.counselstack.com/opinion/doors-on-line-v-chandra-ohioctapp-2023.