Fong v. Faires

2025 Ohio 1032
CourtOhio Court of Appeals
DecidedMarch 25, 2025
Docket24AP-467
StatusPublished
Cited by1 cases

This text of 2025 Ohio 1032 (Fong v. Faires) 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
Fong v. Faires, 2025 Ohio 1032 (Ohio Ct. App. 2025).

Opinion

[Cite as Fong v. Faires, 2025-Ohio-1032.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

Ilan Fong, :

Plaintiff-Appellant, : No. 24AP-467 (C.P.C. No. 23CV-5765) v. : (ACCELERATED CALENDAR) Charles Faires et al., :

Defendants-Appellees. :

D E C I S I O N

Rendered on March 25, 2025

On brief: Walton + Brown, LLP, and Chanda L. Brown, for appellant. Argued: Chanda L. Brown.

On brief: Curry Roby, LLC, and Edwin J. Hollern, for appellee, American National Property & Casualty Company. Argued: Edwin J. Hollern.

On brief: Carol K. Metz and Timothy McKay, for appellee, The Standard Fire Insurance Company. Argued: Timothy McKay.

APPEAL from the Franklin County Court of Common Pleas

DINGUS, J. {¶ 1} Plaintiff-appellant, Ilan Fong, appeals from a judgment of the Franklin County Court of Common Pleas granting the motions for summary judgment of defendants-appellees, American National Property and Casualty Company (“American National”) and The Standard Fire Insurance Company (“Standard Fire”). For the following reasons, we reverse and remand. No. 24AP-467 2

I. Facts and Procedural History {¶ 2} On August 30, 2021, Fong filed an action against Charles Faires and American National, Fong’s underinsurance carrier, alleging he sustained bodily injury due to Faires’ negligent operation of a motor vehicle on August 31, 2019. On September 8, 2021, service was completed on American National. Service was not completed as to Faires. On November 10, 2021, Faires’ counsel filed a suggestion of death, indicating Faires died on April 19, 2020. On August 16, 2022, the trial court dismissed the action, without prejudice, pursuant to Civ.R. 25(A)(1), based on Fong’s failure to substitute Faires’ estate as a party within 90 days of November 10, 2021. {¶ 3} On August 14, 2023, Fong refiled his complaint against Faires and American National. On August 30, 2023, Fong filed a suggestion of Faires’ death, and a motion for substitution of party pursuant to Civ.R. 25, seeking to have himself, as the special administrator for Faires’ estate, substituted as the proper party. Two days later, American National moved to dismiss the refiled complaint as time barred. On January 22, 2024, Standard Fire moved to intervene and join American National’s motion to dismiss the action as time barred. {¶ 4} In May 2024, the trial court denied Fong’s motion to substitute and granted Standard Fire’s motion to intervene. As to the motion to substitute, the trial court reasoned that because Faires died before the commencement of litigation, substitution of Faires’ estate pursuant to Civ.R. 25 would not be proper. The trial court also converted the motions to dismiss to motions for summary judgment. On July 8, 2024, the trial court granted the motions for summary judgment. {¶ 5} Fong timely appeals.

II. Assignment of Error {¶ 6} Fong assigns the following sole assignment of error for our review: The trial court erred in granting the Motion[s] for Summary Judgment, as Appellant properly utilized Ohio’s savings statute, R.C. 2305.19. No. 24AP-467 3

III. Discussion {¶ 7} In his sole assignment of error, Fong contends the trial court erred in granting appellees’ motions for summary judgment because it improperly applied Ohio’s saving statute, R.C. 2305.19. We agree. {¶ 8} An appellate court reviews summary judgment under a de novo standard. Estate of Sample v. Xenos Christian Fellowship, Inc., 2021-Ohio-3898, ¶ 9 (10th Dist.). Summary judgment is appropriate only when the moving party demonstrates (1) no genuine issue of material fact exists, (2) the moving party is entitled to judgment as a matter of law, and (3) reasonable minds could come to but one conclusion and that conclusion is adverse to the party against whom the motion for summary judgment is made, that party being entitled to have the evidence most strongly construed in its favor. Civ.R. 56(C); State ex rel. Grady v. State Emp. Relations Bd., 78 Ohio St.3d 181, 183 (1997). {¶ 9} Pursuant to Civ.R. 56(C), the moving party bears the initial burden of informing the trial court of the basis for the motion and identifying those portions of the record demonstrating the absence of a material fact. Dresher v. Burt, 75 Ohio St.3d 280, 293 (1996). However, the moving party cannot discharge its initial burden under this rule with a conclusory assertion that the nonmoving party has no evidence to prove its case; the moving party must specifically point to evidence of the type listed in Civ.R. 56(C) affirmatively demonstrating that the nonmoving party has no evidence to support the nonmoving party’s claims. Id.; Vahila v. Hall, 77 Ohio St.3d 421, 429 (1997). Once the moving party discharges its initial burden, summary judgment is appropriate if the nonmoving party does not respond, by affidavit or as otherwise provided in Civ.R. 56, with specific facts showing that a genuine issue exists for trial. Dresher at 293; Vahila at 430; Civ.R. 56(E). {¶ 10} Here, at issue is whether Fong’s claims were legally barred as untimely filed. Generally, “an action for bodily injury or injuring personal property shall be brought within two years after the cause of action accrues.” R.C. 2305.10(A). Personal injury claims arising from a motor vehicle accident accrue on the day of the accident, and thus the statute of limitations for such claims expires two years after the accident. Middleton v. Erie Ins., 2022-Ohio-2486, ¶ 9 (10th Dist.). Because this matter involves claims arising from a motor vehicle accident, the statute of limitations for Fong’s claims expired two years after the No. 24AP-467 4

accident. The motor vehicle accident occurred on August 31, 2019, and therefore the applicable statute of limitations expired August 31, 2021. {¶ 11} The parties dispute whether the requirements of the “saving statute,” R.C. 2305.19, were established to provide an exception to the two-year statute of limitations applicable to Fong’s personal injury claims. R.C. 2305.19 permits “plaintiffs to refile lawsuits in certain situations after the applicable statute of limitations expires.” McCullough v. Bennett, 2024-Ohio-2783, ¶ 11. The statute provides, in pertinent part: “In any action that is commenced or attempted to be commenced, . . . if the plaintiff fails otherwise than upon the merits, the plaintiff . . . may commence a new action within one year after the date of . . . plaintiff’s failure otherwise than upon the merits or within the period of the original applicable statute of limitations, whichever occurs later.” R.C. 2305.19(A). By allowing additional time for a plaintiff to refile an action, this statute “acts as an exception to the general bar of the statute of limitations” and is “intended to provide a litigant an adjudication on the merits.” Wilson v. Durrani, 2020-Ohio-6827, ¶ 11. “For the savings statute to apply, an action must fail other than on the merits and then the plaintiff must commence a new action within one year of that failure.” Moore v. Mt. Carmel Health Sys., 2020-Ohio-4113, ¶ 9, citing R.C. 2305.19(A). Additionally, the original action and the new action must be “substantially the same.” Children’s Hosp. v. Ohio Dept. of Pub. Welfare, 69 Ohio St. 2d 523, 525 (1982). Ultimately, in determining the applicability of the saving statute, we must remain mindful that it “ ‘is a remedial statute and is to be given a liberal construction to permit the decision of cases upon their merits rather than upon mere technicalities of procedure.’ ” Byers v. Robinson, 2008-Ohio-4833, ¶ 51 (10th Dist.), quoting Cero Realty Corp. v. Am. Mfrs. Mut. Ins. Co., 171 Ohio St. 82 (1960), paragraph one of the syllabus. {¶ 12} In analyzing the applicability of the saving statute, we first must determine whether Fong’s original action, filed in August 2021, was “commenced or attempted to be commenced.” 2305.19(A).

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Bluebook (online)
2025 Ohio 1032, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fong-v-faires-ohioctapp-2025.