Forsyth Fin., L.L.C. v. Chaney

2024 Ohio 1691, 244 N.E.3d 564
CourtOhio Court of Appeals
DecidedMay 2, 2024
Docket113099
StatusPublished

This text of 2024 Ohio 1691 (Forsyth Fin., L.L.C. v. Chaney) 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
Forsyth Fin., L.L.C. v. Chaney, 2024 Ohio 1691, 244 N.E.3d 564 (Ohio Ct. App. 2024).

Opinion

[Cite as Forsyth Fin., L.L.C. v. Chaney, 2024-Ohio-1691.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

FORSYTHE FINANCE, LLC, :

Plaintiff-Appellant, : No. 113099 v. :

DANNETTE CHANEY, :

Defendant-Appellee. :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED RELEASED AND JOURNALIZED: May 2, 2024

Civil Appeal from the Cuyahoga County Court of Common Pleas Case No. CV-20-939904

Appearances:

Tucker Ellis LLP and Elisabeth C. Arko; Andrew P. Trevino, pro hac vice, and Sarah Butler, pro hac vice, for appellant.

Frederick & Berler, LLC, Ronald I. Frederick, and Michael L. Berler, for appellee.

MARY EILEEN KILBANE, P.J.:

Plaintiff-appellant Forsythe Finance, LLC (“Forsythe”) appeals from

the trial court’s order granting defendant-appellee Dannette Chaney’s (“Chaney”) motion for judgment on the pleadings. For the following reasons, we affirm the

judgment of the lower court.

Factual and Procedural History

In January 2014, Chaney purchased a 2005 Chevrolet Equinox (“the

vehicle”) from Brian’s Direct Detail (“BDD”). As is standard in a motor vehicle

purchase, Chaney signed multiple documents as part of the transaction. Chaney

signed a bill of sale, as well as a document that referred to itself as a “Precomputed

Retail Installment Contract” and a “Precomputed Interest Retail Installment Sales

Contract” (“RISC”).

Subsequently, BDD assigned its interest in the RISC to AC Autopay

LLC (“AC”). On or about July 3, 2014, Chaney defaulted on the RISC. On July 8,

2015, AC repossessed the vehicle and ultimately sold it at auction in November 2015.

AC then sold its interest in the RISC to Security Credit Services, LLC, which in turn

then sold its interest in the RISC to Forsythe in November 2018. Forsythe then

sought to collect upon the RISC by initiating the underlying action.

On January 21, 2020, Forsythe filed a complaint in the Garfield

Heights Municipal Court against Chaney to collect a consumer debt for Chaney’s

breach of the RISC. On June 1, 2020, Chaney responded by filing a class action

counterclaim. On September 4, 2020, the case was transferred to the Cuyahoga

County Court of Common Pleas.

On August 29, 2022, Chaney filed a Civ.R. 12(C) motion for judgment

on the pleadings, asserting that Forsythe filed its complaint after the expiration of the four-year statute of limitations applicable to the sale of goods under R.C.

1302.98.

On May 1, 2023, the trial court granted Chaney’s Civ.R. 12(C) motion

and dismissed the action. In a corresponding journal entry, the court held:

[T]he three-page all-inclusive instrument entitled “Precomputed Retail Installment Contract,” the only contract in the record, is governed by Ohio’s four-year statute of limitations pertaining to the breach of a contract of sale. R.C. 1302.98. Forsythe’s complaint was filed at least four years after the accrual of the cause of action and well beyond the applicable four-year statute of limitations.

Forsythe filed a timely notice of appeal and raises a single assignment

of error for our review:

The trial court erred when it granted Chaney’s motion for judgment on the pleadings by failing to construe the pleadings and attached contracts in Forsythe’s favor and incorrectly applying the four-year sale of goods statute of limitations under Chapter 1302 of the Ohio Revised Code instead of the six-year statute of limitations for security transactions under Chapter 1309.

Legal Analysis

Forsythe’s sole assignment of error challenges the trial court’s grant

of Chaney’s motion for judgment on the pleadings based on the statute of

limitations.

Under Civ.R. 12(C), “[a]fter the pleadings are closed but within such

time as not to delay the trial, any party may move for judgment on the pleadings.”

Dismissal of a complaint is appropriate under Civ.R. 12(C) when, “after construing

all material factual allegations in the pleadings as true and all reasonable inferences

that can be drawn therefrom in favor of the plaintiff, the court finds, beyond doubt, that the plaintiff could prove no set of facts in support of his or her claims that would

entitle the plaintiff to relief.” Crenshaw v. Howard, 2022-Ohio-3914, 200 N.E.3d

335, ¶ 13 (8th Dist.), citing New Riegel Local School Dist. Bd. of Edn. v. Buehrer

Group Architecture & Eng., Inc., 157 Ohio St.3d 164, 2019-Ohio-2851, 133 N.E.3d

482, ¶ 8, citing State ex rel. Midwest Pride IV, Inc. v. Pontious, 75 Ohio St.3d 565,

570, 664 N.E.2d 931 (1996). A motion for judgment on the pleadings raises only

questions of law, testing the legal sufficiency of the claims asserted. Id., citing

Johnson v. Johnson, 8th Dist. Cuyahoga No. 108420, 2020-Ohio-1381, ¶ 11.

Therefore, we review a trial court’s decision to grant a motion for judgment on the

pleadings de novo. Id., citing New Riegel at ¶ 8, citing Rayess v. Educational

Comm. for Foreign Med. Graduates, 134 Ohio St.3d 509, 2012-Ohio-5676, 983

N.E.2d 1267, ¶ 18.

In support of its argument that the trial court erred in granting

Chaney’s motion for judgment on the pleadings, Forsythe asserts that the trial court

failed to apply the correct statute of limitations. Specifically, Forsythe argues that

the trial court applied Article 2 of the Uniform Commercial Code (“UCC”), as

codified in Chapter 1302 of the Ohio Revised Code, which provides for a four-year

statute of limitations on contracts for the sale of goods. Forsythe argues that the

trial court should have applied Article 9 of the UCC, as codified in Chapter 1309 of

the Ohio Revised Code, which provides for a six-year statute of limitations for

secured transactions. According to Forsythe, this error by the trial court arose from the trial

court’s decision to consider only the RISC, while ignoring the bill of sale.1

Pursuant to R.C. 1317.01(L), a retail installment contract “means any

written instrument that is executed in connection with any retail installment sale

and is required by section 1317.02 of the Revised Code or is authorized by section

1317.03 of the Revised Code, and includes all such instruments executed in

connection with any retail installment sale.”

R.C. 1302.98 provides, in relevant part, “[a]n action for breach of any

contract for sale must be commenced within four years after the cause of action has

accrued.” Ohio courts, including this court, have held that RISCs executed in similar

circumstances to those in this case are governed by the four-year statute of

limitations in R.C. 1302.98. For example, this court applied the four-year statute of

limitations in a case in which a consumer had purchased a vehicle pursuant to a

retail installment contract. Foster v. Wells Fargo Fin. Ohio, Inc., 195 Ohio App.3d

497, 2011-Ohio-4632, 960 N.E.2d 1022, ¶ 14 (8th Dist.). Likewise, the Eleventh

District has held that the four-year statute of limitations applied to an action based

on a consumer’s default on an installment sales contract related to the purchase of

a used vehicle. D.A.N. Joint Venture III, L.P. v. Armstrong, 11th Dist. Lake No.

2006-L-089, 2007-Ohio-898, ¶ 34. Specifically, the court held that even though

some courts have applied a six-year statute of limitations to causes of action arising

1 We note that Forsythe never refers to the RISC specifically as a RISC, instead

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Related

Foster v. Wells Fargo Financial Ohio, Inc.
2011 Ohio 4632 (Ohio Court of Appeals, 2011)
Johnson v. Johnson
2020 Ohio 1381 (Ohio Court of Appeals, 2020)
State ex rel. Midwest Pride IV, Inc. v. Pontious
664 N.E.2d 931 (Ohio Supreme Court, 1996)
Crenshaw v. Howard
2022 Ohio 3914 (Ohio Court of Appeals, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 1691, 244 N.E.3d 564, Counsel Stack Legal Research, https://law.counselstack.com/opinion/forsyth-fin-llc-v-chaney-ohioctapp-2024.