Goldfarb v. Cuyahoga Cty. Dept. of Pub. Works

2025 Ohio 3283
CourtOhio Court of Appeals
DecidedSeptember 11, 2025
Docket114721
StatusPublished
Cited by1 cases

This text of 2025 Ohio 3283 (Goldfarb v. Cuyahoga Cty. Dept. of Pub. Works) 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
Goldfarb v. Cuyahoga Cty. Dept. of Pub. Works, 2025 Ohio 3283 (Ohio Ct. App. 2025).

Opinion

[Cite as Goldfarb v. Cuyahoga Cty. Dept. of Pub. Works, 2025-Ohio-3283.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

AUSTIN GOLDFARB, :

Plaintiff-Appellee, : No. 114721 v. :

CUYAHOGA COUNTY, : DEPARTMENT OF PUBLIC WORKS, : Defendant-Appellant.

JOURNAL ENTRY AND OPINION

JUDGMENT: REVERSED RELEASED AND JOURNALIZED: September 11, 2025

Civil Appeal from the Cuyahoga County Court of Common Pleas Case No. CV-24-991175

Appearances:

Taubman Law and Bruce D. Taubman, for appellee.

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, and Regina A. Russo and Michael J. Stewart, Assistant Prosecuting Attorneys, for appellant.

EILEEN T. GALLAGHER, P.J.:

Appellant Cuyahoga County Department of Public Works (“the

County”) appeals the judgment of the trial court denying summary judgment on

appellee Austin Goldfarb’s (“Goldfarb”) complaint for negligence. The County assigns one error for our review: the trial court erred when it denied the County’s

motion for summary judgment, denying it the benefit of political-subdivision

immunity under R.C. Ch. 2744. After a thorough review of the applicable law and

facts, we reverse the judgment of the trial court.

I. Factual and Procedural History

Goldfarb owns a home on West 45th Street in Parma, Ohio. In August

2021, Goldfarb called the County to investigate an odor in his home. Approximately

one week later, employees of the County’s Department of Public Works’ Lateral

Service Department came to Goldfarb’s home. They observed that a sanitary tee,

which gave the County access to the lateral line of the sewer system, was broken. In

order to repair the issue, the workers had to pull out a “plug” of grass and dirt in

Goldfarb’s front yard.

Two days later, the County’s construction crew went to Goldfarb’s home

to replace the broken tee. The construction crew determined that the sanitary tee

was not actually broken but that the lateral line was blocked with grease. The

construction crew then asked the Sanitary Jet Department to remove the grease and

debris from the lateral line. The Jet Department came to Goldfarb’s property to

perform the work three days later.

Either Goldfarb or his fiancée were at home for two of the three visits

by the County workers. However, Goldfarb did not know what work had been

performed and did not check his lawn to see where the repair had been made. He

was aware, though, that the issue that had caused the odor had been remedied. Over the next several weeks, Goldfarb continued to use his yard and

mow his lawn. He noticed that the grass was discolored where the repair work had

taken place. The grass on the plug was dead and looked different than the grass

around it.

Approximately five weeks after the work in his yard had been

performed, Goldfarb walked across the yard in the early morning hours to get to his

vehicle, which was parked on the street, in order to go to work. While he was walking

in the yard, Goldfarb fell on his lawn, injuring his ankle, leg, and back. He surmised

that he had fallen in the place where the County workers had removed the “plug”

from his lawn. Later that day, he took pictures of the area where he had fallen.

Goldfarb filed a complaint against the County alleging that he was

injured after the County “failed to observe due care and properly repack the hole

that was dug to fix the water line.” Goldfarb asserted that the County was reckless,

careless, and negligent.

The County answered Goldfarb’s complaint, denying the allegations

and raising the defense of political-subdivision immunity under R.C. Ch. 2744. The

County filed a motion for summary judgment, arguing that it was immune from

liability because the workers were engaging in a governmental function. It further

argued that even if the workers were engaged in a proprietary action, Goldfarb’s

claim would still fail because he could not demonstrate the negligence exception to

immunity under R.C. 2744.02(B)(2). Specifically, the County asserted that

(1) Goldfarb did not offer any expert testimony to establish the appropriate standard of care; and (2) Goldfarb was comparatively negligent because the hazard was open

and obvious. In support of its motion, the county offered the deposition testimony

of Goldfarb, along with an affidavit and deposition testimony of Michael Holt

(“Holt”), a sewer maintenance supervisor at the County.

In his affidavit, Holt referred to the Sewer Maintenance Division’s

Standard Operating Procedures Manual (“manual”), which was also attached to his

affidavit. He explained that the manual “describes step-by-step actions employees

must take to perform the various tasks of the Division.” (Holt Affidavit, ¶ 8.) Holt

did not describe the actual work performed at Goldfarb’s residence but outlined the

standard operating procedure from the manual for performing the type of work that

was done at Goldfarb’s residence. He stated the following:

10. LS-01 in Exhibit B describes the standard operating procedure for locating storm and/or sanitary test tees on an owner’s property.

11. On page 5 of LS-01 in Exhibit B, the standard operating procedure states, “[o]nce test tees have been located, place sewer lateral test tee caps back on each test tee and when necessary, replace in kind/cover each test tee with dirt/grass.”

12. It is standard operating procedure for the Department of Public Works to replace in kind/cover each test tee with dirt/grass, essentially replacing exactly what they took out of the area. This generally involves a “plug” of sod material that has been removed.

(Id. at ¶ 10-12.)

Holt further stated in his affidavit that he had observed the

photographs Goldfarb had taken of the area where the work had been performed

and, “[i]n [his] opinion, the area was normal and provided no unnecessary danger to the homeowner.” (Id. at ¶ 13.) He additionally averred that the pictures

“reflect[ed] a minor disturbance, not one that would necessitate lawn repair.” (Id.

at ¶ 14.)

Goldfarb filed a brief in opposition to the motion for summary

judgment, arguing that the County had a duty to properly refill and repack the hole

that it had dug in his yard. He asserted that there was a genuine issue of material

fact as to whether the County breached that duty by improperly repairing the hole.

Goldfarb offered his own affidavit in support, wherein he acknowledged that he had

mowed his lawn using a self-propelled mower several times between the

maintenance repair and the day of his injury but denied that the repaired hole was

open and obvious. He stated in his deposition that he had “probably” noticed the

area where the repair had been made and said that it “just looked different.” He

further offered photographs of the area that he took after he fell, demonstrating the

size and visibility of the repaired area.

In his brief, Goldfarb argued that he did not need expert testimony to

support his simple negligence claim. Further, Goldfarb objected to the County’s use

of Holt as an expert witness, arguing that he had no education or training beyond

that of normal work experience that would have qualified him as an expert.

Moreover, Holt did not work on the project at Goldfarb’s residence nor did he ever

visit the property after the fact.

The County filed a reply brief, arguing that Goldfarb failed to

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