Haery v. Spaeth

2025 Ohio 5801
CourtOhio Court of Appeals
DecidedDecember 30, 2025
DocketCA2024-07-054
StatusPublished

This text of 2025 Ohio 5801 (Haery v. Spaeth) 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
Haery v. Spaeth, 2025 Ohio 5801 (Ohio Ct. App. 2025).

Opinion

[Cite as Haery v. Spaeth, 2025-Ohio-5801.]

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO

WARREN COUNTY

TRENT HAERY, : CASE NO. CA2024-07-054 Appellant, : OPINION AND : JUDGMENT ENTRY - vs - 12/30/2025 :

JAMES L. SPAETH, CLERK OF : COURTS, WARREN COUNTY, OHIO : Appellee.

CIVIL APPEAL FROM WARREN COUNTY COURT OF COMMON PLEAS Case No. 24-CV-096913

Brunner Quinn, and Rick L. Brunner, Patrick M. Quinn, and Hannah Fard for appellant.

Fishel Downey Albrecht Riepenhoff LLC, and David C. Moser and Makenzie E. McAfee, for appellee.

____________ OPINION

BYRNE, J.

{¶ 1} Trent Haery appeals from the decision of the Warren County Court of

Common Pleas, General Division, which dismissed his complaint against James L. Warren CA2024-07-054

Spaeth, in his official capacity as the elected Clerk of Courts of Warren County, Ohio ("the

Clerk").1 For the reasons described below, we affirm.

I. Factual and Procedural Background

{¶ 2} This case was resolved on the pleadings pursuant to a Civ.R. 12(B)(6)

motion to dismiss. The following facts are derived from the complaint and any attached

exhibits and are undisputed for purposes of this appeal. Fontain v. H&R Cincy Properties,

L.L.C., 2022-Ohio-1000, ¶ 55 (12th Dist.) ("In ruling on a complaint under Civ.R. 12(B)(6),

the trial court must presume that all factual allegations in the complaint are true and draw

all reasonable inferences in favor of the nonmoving party.").

{¶ 3} Haery was one of multiple financial crime victims in two criminal

prosecutions in the Warren County Court of Common Pleas. The total loss to the victims

was approximately $800,000. The defendants in the two cases paid $300,000 in partial

restitution. In November 2023, the Warren County Court of Common Pleas issued a

restitution order directing distribution of the $300,000 to the various victims, on a pro rata

basis.

{¶ 4} According to the court's restitution order, Haery's pro rata share of restitution

was $15,075.38. Shortly after the court issued its restitution order, the Clerk issued two

restitution checks to Haery totaling the incorrect amount of $40,000.00, rather than the

correct $15,075.38 amount ordered by the court. In fact, the Clerk erroneously issued to

multiple crime victims restitution checks in amounts that were inconsistent with the

amounts stated in the restitution order. As a result, some crime victims received more

than they were entitled to, and some received less.

1. James L. Spaeth ended his term as Warren County Clerk of Courts in January 2025. Spaeth was replaced by a newly-elected clerk, Breighton Smith. Spaeth, not Smith, was the Clerk during the events at issue in this appeal. -2- Warren CA2024-07-054

{¶ 5} When Haery received the restitution checks he contacted the Clerk's office.

The Clerk's office confirmed to Haery that the checks had been issued to him and that

the amount of the payments he received, $40,000.00, was correct. Haery then deposited

the restitution checks into his personal bank account. He began issuing checks of his

own, spending the deposited restitution money he received from the Clerk.

{¶ 6} Unbeknownst to Haery, the Clerk's office discovered it had issued restitution

checks to the various crime victims in incorrect amounts, and, on December 4, 2023, the

Clerk issued stop-payment orders on the two incorrect restitution checks issued to Haery.

{¶ 7} On December 6, 2023, the Clerk contacted Haery by email notifying him of

the error and the stop-payment order. However, as stated above, Haery had already

issued personal checks spending some of the deposited restitution money. According to

Haery, his personal bank account "went from a positive balance of $22,00[0].00 to a

negative balance of [$]18,000.00 as a result of the stop payment order" as of December

10, 2023. According to a later trial court entry, the Clerk eventually paid Haery $9,436.36.

{¶ 8} In January 2024, Haery filed a complaint against the Clerk, asserting five

causes of action based on the above facts. In Count One, Haery alleged that the two

restitution checks were "wrongfully dishonored" without timely notice to Haery. In Count

Two, Haery alleged that the Clerk acted with reckless disregard and/or negligence by

treating him "worse or disparately" from other victims. In Count Three, Haery alleged that

the Clerk intentionally caused him injury by failing to notify him of the stop-payment order

and by treating him worse or disparately from other victims. In Count Four, Haery alleged

entitlement to specific performance and "payment for full face amounts of the checks." In

Count Five, Haery alleged that the Clerk's actions had "slandered the credit and/or

damaged the credit standing of [Haery]." In sum, Haery demanded a money judgment

-3- Warren CA2024-07-054

against the Clerk exceeding $25,000, specific performance (delivery of the original

restitution check amounts), attorney fees, interest, and court costs.

{¶ 9} The Clerk moved to dismiss the complaint pursuant to Civ.R. 12(B)(6). The

Clerk made two main arguments. First, the Clerk argued that Haery's Complaint failed to

state a claim for which relief could be granted because none of the five causes of action

described in the Complaint were cognizable claims supported by any statute or common

law doctrine. Second, the Clerk argued that, even if Haery did state one or more

cognizable claims, he and his office were entitled to absolute judicial or quasi-judicial

immunity from those claims. In support, the Clerk argued that the actions of issuing

checks for court-ordered restitution arose out of the performance of judicial or quasi-

judicial activities and that court clerks have absolute immunity for these activities under

well-settled law.

{¶ 10} Haery filed a memorandum opposing the Clerk's motion to dismiss. In

response to the Clerk's first argument, Haery argued that his complaint set forth

cognizable claims in sufficient particularity to meet the requirements of notice pleading.

In response to the Clerk's immunity argument, Haery argued that the actions of issuing a

check and ordering a stop-payment were purely ministerial and clerical acts and were not

related to judicial or quasi-judicial functions. Therefore, he argued, the Clerk's office was

not entitled to judicial or quasi-judicial immunity.

{¶ 11} The trial court granted the Clerk's motion to dismiss. The court found that

Haery "fail[ed] to set forth in requisite detail what his causes of action are" and found that

"none of [Haery's] so-called claims constitutes a cognizable cause of action" under Ohio

law. Next, with respect to the immunity question, the court found that the payment of

restitution to a crime victim was a judicial function or quasi-judicial function for which the

Clerk was entitled to immunity. The court noted that the common pleas court had given

-4- Warren CA2024-07-054

the Clerk specific instructions as to how restitution funds were to be distributed to each of

the victims. The court found that the Clerk was engaged in the performance of the court's

functions and was therefore entitled to absolute immunity.

{¶ 12} Haery appealed, raising a single assignment of error.

II. Law and Analysis

{¶ 13} Haery's assignment of error states:

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Bluebook (online)
2025 Ohio 5801, Counsel Stack Legal Research, https://law.counselstack.com/opinion/haery-v-spaeth-ohioctapp-2025.