Gurary v. John Carroll Univ.

2024 Ohio 3114, 251 N.E.3d 271
CourtOhio Court of Appeals
DecidedAugust 15, 2024
Docket113698
StatusPublished
Cited by7 cases

This text of 2024 Ohio 3114 (Gurary v. John Carroll Univ.) 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
Gurary v. John Carroll Univ., 2024 Ohio 3114, 251 N.E.3d 271 (Ohio Ct. App. 2024).

Opinion

[Cite as Gurary v. John Carroll Univ., 2024-Ohio-3114.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

JONATHAN GURARY, :

Plaintiff-Appellant, : No. 113698

v. :

JOHN CARROLL UNIVERSITY, :

Defendant-Appellee. :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED IN PART; REVERSED IN PART; REMANDED RELEASED AND JOURNALIZED: August 15, 2024

Civil Appeal from the Lyndhurst Municipal Court Case No. 23CVF00232

Appearances:

Jonathan Gurary, pro se.

Freeman, Mathis & Gary, LLP and Steven J. Forbes, for appellee.

EILEEN A. GALLAGHER, P.J.:

In this accelerated appeal, plaintiff-appellant, Jonathan Gurary,

appeals the trial court’s order granting summary judgment in favor of defendant-

appellee, John Carroll University (“JCU”), on his claims of breach of contract,

promissory estoppel and fraud, arising out of JCU’s failure to pay Gurary, as part of an across-the-board salary reduction, that which it had contracted to pay him.

Gurary contends that the trial court abused its discretion in its “handling of

[d]iscovery,” erred in excluding an affidavit he submitted to support his claims on

summary judgment and erred in granting summary judgment on all his claims in

favor of JCU.

For the reasons that follow, we affirm the trial court on Gurary’s

promissory estoppel and fraud claims, reverse the trial court on Gurary’s breach-of-

contract claim and remand for further proceedings.

Procedural and Factual Background1

On or about April 27, 2020, Gurary, a nontenured faculty member,

and JCU entered into an employment contract (the “agreement” or the “contract”)

for the 2020-2021 academic year.2 Pursuant to their agreement, Gurary was to be

employed full-time at JCU “with the academic rank of Assistant Professor,

Department of Mathematics and Computer Science.” (Emphasis deleted.) Gurary

agreed “to conduct such classes, extracurricular activities, and administrative work

during said year assigned to him by the Administrators of the college or school in

which he [was] assigned to teach and to render these services in a scholarly and

efficient manner to the satisfaction of said officers.” “In consideration for said

services,” JCU agreed to pay Gurary a salary of $71,000 “in twelve equal payments

1 The facts set forth herein are based on the admissions in JCU’s answer and the

documents submitted with JCU’s motion for summary judgment.

2 The record reflects that JCU mailed a proposed contract to Gurary in mid-March

2020 and that Gurary signed it and sent it back to JCU on, or around, April 27, 2020. on a monthly basis, with the first payment to be made on the 30th day of September.”

The contract further provided that “[i]t is understood and agreed by the parties

hereto that this agreement shall be interpreted and construed in the light of the

provisions of the Faculty Handbook of John Carroll University which are in force at

the time it is issued.”

On or about May 29, 2020, JCU’s President, Michael Johnson, sent

an email to all faculty members and staff advising them that JCU would be

“implement[ing] a salary reduction program for a 12-month period” for all

employees and faculty members making at least $40,000. Salary reductions were

to be implemented on a tiered basis. Faculty members making $70,000-$99,999

would receive “a 7% pay cut,” “reduced on a temporary basis for the 2020-21

academic year, effective as of the September 2020 payroll period and extending

through August 31, 2021.” According to the email, the salary reductions were being

implemented “[i]n order to maintain our fiscal strength and avoid reaching the point

of financial instability” during the COVID-19 pandemic. “All temporary savings”

would be “reevaluated in advance of the 2021-22 fiscal year.”

As a result of its salary reduction program, JCU reduced Gurary’s

salary for the 2020-2021 academic year by $4,970 to $66,030. Gurary did not agree

to the reduction in his salary and no written modification of the contract was entered

into between Gurary and JCU reflecting this change.

On or about September 3, 2021, JCU’s Human Resources

Department sent an email to Gurary stating that he would receive “a one-time retention bonus payment in the amount of $3,475.26 in [his] pay on September 30.”

The email provided the following explanation of the “retention bonus payment”:

About the Retention Bonus

John Carroll University applied for federal assistance available to higher education institutions via the Coronavirus Aid, Relief, and Economic Security (CARES) Act. We were fortunate to receive federal funds that allowed us to offset some revenue losses and increased expenses due to COVID-19.

We recognize that John Carroll was able to sustain operations and focus on our students because of financial sacrifices and savings made by employees, including the reduction of salary that impacted staff and faculty earning over $40,000 per year. As such, federal funding from the Employee Retention Credit (ERTC), a provision of the CARES Act, will be shared with staff and faculty who were impacted by salary reductions in 2020-2021 and who remain committed to employment with the University now and into the future.

This retention bonus amount represents your proportionate share of the ERTC grant in relation to the reduction in salary you experienced.

University employees who will be actively employed on September 30, 2021, will receive the bonus. If you provide notice or indicate your intention to resign from the University on or prior to September 30, 2021, you are not eligible for the retention bonus.

The payment will be issued to you as a cash bonus. . . .

(Emphasis in original.) Gurary continued to be employed by JCU, and, in or around

September 30, 2021, JCU paid Gurary a $3,475.26 “retention bonus.”

On January 31, 2023, Gurary, pro se, filed a small claims complaint

in the Lyndhurst Municipal Court against JCU, seeking to recover $4,970 in

damages plus interest and costs for the reduction in his contracted salary during the

2020-2021 academic year. On April 5, 2023, JCU filed a motion to transfer the case from the small claims docket to the regular docket along with a demand for a jury

trial. The trial court granted the motion, and the case was transferred to the regular

docket.

On May 8, 2023, Jennifer Rick, JCU’s Assistant Vice President,

Human Resources, sent a letter to Gurary, advising him that “due to a calculation

error,” he was one of six employees “who did not receive a retention bonus payment

amount” in 2021 “that represented an amount that was equivalent to the reduction

in salary in the 2020-2021 academic year” and that, “[a]s a result,” JCU was “issuing

to those affected employees a supplemental bonus payment in the pay in May 2023.”

She stated that Gurary was entitled to receive a “one-time bonus payment in the

amount of $1,494.74” as a cash bonus. In her letter, Rick described the purpose of

the 2021 “retention bonus payment” as follows:

The bonus was made in gratitude for the continuing work by those who were impacted by salary reductions in the 2020-21 academic year and who remained committed to employment with the University at that time and into the future.

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Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 3114, 251 N.E.3d 271, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gurary-v-john-carroll-univ-ohioctapp-2024.