Girdler v. Libassi

2022 Ohio 1846
CourtOhio Court of Appeals
DecidedJune 2, 2022
Docket111111
StatusPublished

This text of 2022 Ohio 1846 (Girdler v. Libassi) 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
Girdler v. Libassi, 2022 Ohio 1846 (Ohio Ct. App. 2022).

Opinion

[Cite as Girdler v. Libassi, 2022-Ohio-1846.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

ANNETTE GAYLE GIRDLER, :

Plaintiff-Appellant, : No. 111111 v. :

PATRICIA D. LIBASSI, ET AL., :

Defendants-Appellees. :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED RELEASED AND JOURNALIZED: June 2, 2022

Civil Appeal from the Cuyahoga County Court of Common Pleas Case No. CV-20-932830

Appearances:

Tayfel & Associates, LLC, and Eric W. Tayfel, for appellant.

Pilawa & Brennan Co., LPA, Kimberly A. Brennan, and Dennis M. Pilawa, for appellees.

EILEEN T. GALLAGHER, J.:

Plaintiff-appellant, Annette Gayle Girdler (“Girdler”), appeals an order

granting summary judgment in favor of defendants-appellees, Patricia D. Libassi

and Philip S. Libassi (collectively “the Libassis”). Girdler claims the following two

errors: 1. The trial court erred as a matter of law in granting defendant- appellees’ motion for summary judgment when defendant-appellees were aware of a dangerous condition on their property and affirmatively acted to maintain the dangerous condition which caused plaintiff-appellant’s injury.

2. The trial court erred as a matter of law [by] concluding that the height difference between two squares of concrete sidewalk was conclusively less than two inches and therefore an insubstantial defect.

After reviewing the record and applicable law, we affirm the trial court’s

judgment.

I. Facts and Procedural History

Girdler filed a complaint against the Libassis for personal injuries she

sustained after she tripped and fell on a public sidewalk in front of the Libassis’

home. Girdler alleged that she tripped and fell on the sidewalk because the Libassis

negligently allowed grass to grow between the sidewalk squares and the grass

concealed a difference in height between the two squares. She asserted that the

Libassis negligently failed to maintain the sidewalk in a safe condition and

negligently failed to warn her of the hazardous condition.

After answering the complaint and conducting discovery, the Libassis

filed a motion for summary judgment, arguing that it is the municipality, not the

owner of the adjacent property, that has the duty to maintain public sidewalks in a

safe condition. They further argued that private homeowners are not responsible

for an adjacent sidewalk’s condition unless one of three exceptions applies: (1) a

statute or ordinance imposed a specific duty on the property owner to maintain the

sidewalk in good repair, (2) “‘by affirmative acts [the property owner] created or negligently maintained the defective or dangerous condition causing the injury’”; or

(3) the property owner “‘negligently permitted the defective or dangerous condition

to exist for some private use or benefit.’” (Defendants’ motion for summary

judgment p. 5, quoting Donnelly v. Berea, 8th Dist. Cuyahoga No. 108753, 2020-

Ohio-2722, ¶ 13.) The Libassis argued that because none of the exceptions were

applicable in this case, they were entitled to judgment as a matter of law. They also

argued that the height deviation between the two sidewalk squares was less than two

inches and the condition on the sidewalk was open and obvious, thus absolving them

of liability.

Girdler filed a cross-motion for partial summary judgment, arguing the

Libassis knew the sidewalk was uneven and that grass growing between the slabs of

concrete concealed the difference in elevation of the sidewalk near where Girdler

tripped and fell. She further asserted that although private homeowners generally

have no duty to maintain public sidewalks, the Libassis were liable for her injuries

because they created or negligently maintained a dangerous condition that

proximately caused her injury.

The trial court granted the Libassis’ motion for summary judgment on

the grounds that none of the three exceptions enumerated in Donnelly, which confer

liability on private property owners, were applicable. The trial court also found that

the difference in elevation of the sidewalk squares measured less than two inches

and there were no attendant circumstances that would turn an otherwise minor

defect into a substantial or dangerous condition. By granting the Libassis’ motion for summary judgment in total, it implicitly overruled Girdler’s partial motion for

summary judgment. Girdler now appeals the trial court’s judgment.

II. Law and Analysis

A. Standard of Review

Appellate review of summary judgments is de novo. Grafton v. Ohio

Edison Co., 77 Ohio St.3d 102, 105, 671 N.E.2d 241 (1996). Pursuant to Civ.R. 56(C),

summary judgment is appropriate when (1) there is no genuine issue of material

fact; (2) the moving party is entitled to judgment as a matter of law; and (3)

reasonable minds can come to but one conclusion and that conclusion is adverse to

the nonmoving party, said party being entitled to have the evidence construed most

strongly in his or her favor. Horton v. Harwick Chem. Corp., 73 Ohio St.3d 679,

653 N.E.2d 1196 (1995), paragraph three of the syllabus; Zivich v. Mentor Soccer

Club, 82 Ohio St.3d 367, 696 N.E.2d 201 (1998).

B. Affirmative Act of Negligence

In the first assignment of error, Girdler argues the trial court erred in

granting the Libassis’ motion for summary judgment on her negligence claim

because the evidence showed that they were aware of a dangerous condition and

affirmatively acted to maintain the dangerous condition.

To prevail on a negligence claim, Girdler had to establish that the

Libassis owed her a duty, that they breached that duty, and that the breach of that

duty proximately caused her injuries. Tyler v. Cleveland, 129 Ohio App.3d 441, 444, 717 N.E.2d 1175 (8th Dist.1998). In this case, the trial court found that the Libassis

did not owe Girdler a duty of care to maintain the sidewalk in good repair.

Sidewalks on public streets are presumed to be “under the control of

the municipality or public authority.” Eichorn v. Lustig’s, Inc., 161 Ohio St. 11, 13,

117 N.E.2d 436 (1954). Thus, abutting landowners generally owe no duty to

pedestrians for the condition of a public sidewalk. Id. However, there are

exceptions to the general rule propounded in Eichorn, and adjacent property owners

may be liable for injuries sustained on public sidewalks if one of three exceptions

applies: (1) a statute or ordinance imposes a duty on the property owner to keep the

sidewalks in good repair; (2) “by affirmative acts,” the property owner created or

negligently maintained a defective or dangerous condition that caused injury; or (3)

the property owner negligently allowed the defective or dangerous condition to exist

“‘for some private use or benefit.’” Donnelly, 8th Dist. Cuyahoga No. 108753, 2020-

Ohio-2722, at ¶ 14, quoting Crowe v. Hoffman, 13 Ohio App.3d 254, 255-256, 468

N.E.2d 1120 (6th Dist.1983).

It is undisputed that Girdler tripped and fell on a public sidewalk. And,

Girdler concedes there is no evidence that the Libassis created the uneven sidewalk.

She nevertheless argues the Libassis are liable for her injuries pursuant to the

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Related

Dennison v. Buckeye Parking Corp.
115 N.E.2d 187 (Ohio Court of Appeals, 1953)
Tyler v. City of Cleveland
717 N.E.2d 1175 (Ohio Court of Appeals, 1998)
Crowe v. Hoffman
468 N.E.2d 1120 (Ohio Court of Appeals, 1983)
Horton v. Harwick Chemical Corp.
73 Ohio St. 3d 679 (Ohio Supreme Court, 1995)
Village of Grafton v. Ohio Edison Co.
77 Ohio St. 3d 102 (Ohio Supreme Court, 1996)
Zivich v. Mentor Soccer Club, Inc.
696 N.E.2d 201 (Ohio Supreme Court, 1998)

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Bluebook (online)
2022 Ohio 1846, Counsel Stack Legal Research, https://law.counselstack.com/opinion/girdler-v-libassi-ohioctapp-2022.