Frank v. S.W. Ohio Regional Transit Auth.

2020 Ohio 5497
CourtOhio Court of Appeals
DecidedDecember 2, 2020
DocketC-200015
StatusPublished
Cited by2 cases

This text of 2020 Ohio 5497 (Frank v. S.W. Ohio Regional Transit Auth.) 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
Frank v. S.W. Ohio Regional Transit Auth., 2020 Ohio 5497 (Ohio Ct. App. 2020).

Opinion

[Cite as Frank v. S.W. Ohio Regional Transit Auth., 2020-Ohio-5497.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

EMILY FRANK, : APPEAL NO. C-200015 TRIAL NO. A-1800441 and :

LYNN FRANK, : O P I N I O N.

Plaintiffs-Appellees, :

vs. : SOUTHWEST OHIO REGIONAL TRANSIT AUTHORITY, :

and :

TYRONE PATRICK, :

Defendants-Appellants. :

Civil Appeal From: Hamilton County Court of Common Pleas

Judgment Appealed From Is: Affirmed in Part and Appeal Dismissed in Part

Date of Judgment Entry on Appeal: December 2, 2020

Colombo Law, Dino Colombo and Travis T. Mohler, for Plaintiffs-Appellees,

McCaslin, Imbus & McCaslin, Thomas J. Gruber and Michael P. Cussen, for Defendants-Appellants. OHIO FIRST DISTRICT COURT OF APPEALS

Z A Y A S , Judge.

{¶1} Defendants-appellants, the Southwest Ohio Regional Transit Authority

(“SORTA”) and Tyrone Patrick, appeal the decision of the Hamilton County Court of

Common Pleas denying their motion for summary judgment claiming immunity on

the basis of political subdivision immunity pursuant to R.C. Chapter 2744. We

affirm in part and dismiss in part.

I. Background and Procedural History

{¶2} On January 27, 2016, Emily Frank and her father, Stephen Frank, were

in a crosswalk at the intersection of Erie Avenue and Edwards Road in Cincinnati,

Ohio, when they were struck by a SORTA bus driven by Patrick, a long-time SORTA

bus driver. As a result of the accident, Stephen died, and Emily sustained serious

injuries to her leg.

{¶3} On January 24, 2018, Emily and her mother, Lynn Frank, filed a nine-

count complaint against SORTA and Patrick. Against SORTA, the Franks alleged

negligent training (Count I), negligent entrustment (Count II), negligent retention

(Count III), negligence through vicarious liability (Count V), and negligent infliction

of emotional distress through vicarious liability (Count VII). Against Patrick, the

Franks alleged negligence (Count IV) and negligent infliction of emotional distress

(Count VI). The Franks alleged against both SORTA and Patrick a survivorship claim

(Count VIII) and a wrongful-death claim (Count IX). SORTA and Patrick answered

the complaint, and the parties proceeded with discovery.

{¶4} On November 13, 2019, the Franks filed a motion for leave to amend

their complaint to add allegations of “reckless” conduct or “recklessness” to the

2 OHIO FIRST DISTRICT COURT OF APPEALS

claims against SORTA for negligent training, negligent entrustment, and negligent

retention. On November 14, 2019, SORTA and Patrick filed a motion for summary

judgment. SORTA and Patrick argued that Patrick was immune from the Franks’

suit because he was acting in the scope of his employment and because the record

was “devoid of any evidence that [] Patrick acted with a malicious purpose, in bad

faith, or in a wanton or reckless manner.” SORTA argued that it was immune from

the Franks’ claims of negligent entrustment, negligent training, and negligent

retention under the doctrine of sovereign immunity.

{¶5} On December 17, 2019, the trial court granted the Franks’ motion for

leave to amend their complaint and denied SORTA and Patrick’s motion for

summary judgment. SORTA and Patrick now appeal, asserting three assignments of

error.

II. Analysis

A. The Franks’ Amended Complaint

{¶6} In their first assignment of error, SORTA and Patrick argue that the

trial court erred in allowing the Franks leave to amend their complaint. We find that

we are without jurisdiction to consider this assignment.

{¶7} A court of appeals does not have jurisdiction to rule upon the trial

court’s interlocutory decisions; rather, it has jurisdiction to review final appealable

orders. R.C. 2505.02(B). Generally, a trial court’s order granting a motion for leave

to amend the complaint is an interlocutory order. See Supportive Sols., L.L.C. v.

Electronic Classroom of Tomorrow, 137 Ohio St.3d 23, 2013-Ohio-2410, 997 N.E.2d

490, ¶ 10. However, in circumstances involving political-subdivision immunity, a

political subdivision has the right to an interlocutory appeal under R.C. 2744.02(C)

when the order “denies a political subdivision * * * the benefit of an alleged

3 OHIO FIRST DISTRICT COURT OF APPEALS

immunity from liability as provided in this chapter or any other provision of the law

[it] is a final order.” See id. at ¶ 6.

{¶8} SORTA claims the Franks’ amendment “allows for a possibility of

liability, [which] denied the benefit of the immunity granted under R.C. 2744,” yet

none of the immunities contained in R.C. 2744.03 were affected. Compare

Supportive Solutions at ¶ 17-20 (trial court’s denial of political subdivision’s motion

for leave to file an amended answer to raise the affirmative defense of political-

subdivision immunity deprived the political subdivision from enjoying the benefits of

the alleged immunity). SORTA was required to prove its entitlement to immunity

regardless of whether the Franks were granted leave to amend their complaint to add

allegations regarding recklessness. In other words, the court’s order granting the

Franks’ leave did not foreclose SORTA’s ability to demonstrate alleged immunity and

was therefore not a final order under R.C. 2744.02(C). See Supportive Solutions at ¶

20.

{¶9} Consequently, SORTA and Patrick’s appeal of the trial court’s decision

granting the Franks’ motion for leave to amend their complaint is not properly

before us.

B. Patrick’s Claim of Immunity

{¶10} In their second assignment of error, SORTA and Patrick argue that the

trial court erred in denying summary judgment in favor of Patrick because he was

immune from suit under R.C. Chapter 2744.

{¶11} “We review the denial of sovereign immunity de novo.” Hubbell v.

City of Xenia, 115 Ohio St.3d 77, 2007-Ohio-4839, 873 N.E.2d 878, ¶ 21. We also

review a trial court’s ruling on a motion for summary judgment de novo. See Wal-

Mart Realty Co. v. Tri-Cty. Commons Assoc., LLC, 1st Dist. Hamilton No. C-160747,

4 OHIO FIRST DISTRICT COURT OF APPEALS

2017-Ohio-9280, ¶ 5. Civ.R. 56(C) provides that before summary judgment may be

granted, it must be determined that:

(1) [n]o genuine issue as to any material fact remains to be litigated;

(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 viewing such evidence most strongly in favor of

the party against whom the motion for summary judgment is made,

that conclusion is adverse to that party.

Temple v. Wean United, Inc., 50 Ohio St.2d 317, 327, 364 N.E.2d 267 (1977). The

rule further provides that “[s]ummary judgment shall be rendered forthwith if the

pleadings, depositions, answers to interrogatories, written admissions, affidavits,

transcripts of evidence, and written stipulations of fact, if any, timely filed in the

action, show that there is no genuine issue as to any material fact and that the

moving party is entitled to judgment as a matter of law.” Civ.R. 56(C).

{¶12} “[A] party seeking summary judgment, on the ground that the

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2020 Ohio 5497, Counsel Stack Legal Research, https://law.counselstack.com/opinion/frank-v-sw-ohio-regional-transit-auth-ohioctapp-2020.