Hall v. Hall

2024 Ohio 2569
CourtOhio Court of Appeals
DecidedJuly 3, 2024
DocketL-23-1014
StatusPublished

This text of 2024 Ohio 2569 (Hall v. Hall) 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
Hall v. Hall, 2024 Ohio 2569 (Ohio Ct. App. 2024).

Opinion

[Cite as Hall v. Hall, 2024-Ohio-2569.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT LUCAS COUNTY

Lindsay D. Hall Court of Appeals No. L-23-1014

Appellee Trial Court No. DR020200377

v.

Brian T. Hall DECISION AND JUDGMENT

Appellant Decided: July 3, 2024

*****

Margaret G. Beck, for appellee.

Jeffrey P. Nunnari, for appellant.

ZMUDA, J.

{¶ 1} Appellant, Brian T. Hall, appeals the December 22, 2022 order of the Lucas

County Common Pleas Court, Domestic Division captioned Amended Decision of the

Court and Judgment Entry Granting Divorce. For the following reasons, we find that

appellant’s appeal is untimely under App.R. 4(A)(1) and we therefore dismiss his appeal.

I. Facts and Procedural Background

{¶ 2} The parties to this appeal participated in divorce proceedings that culminated

in the trial court’s granting of divorce through a judgment entry filed on December 20, 2022. Among other things, the judgment entry awarded the entirety of a joint account at

Directions Credit Union to appellee as her separate property and ordered appellee to pay

spousal support to appellant.

{¶ 3} On December 22, 2022, two days after issuing its judgment entry, the trial

court issued an “amended” judgment entry to correct an apparent error regarding which

party was to receive spousal support. The amended judgment entry was identical to the

original judgment entry except that it ordered appellant, rather than appellee, to pay

spousal support.

{¶ 4} Appellant filed his notice of appeal on January 20, 2023—that is, 31 days

after the trial court’s original judgment and 29 days after the trial court’s amended

judgment.

{¶ 5} On March 2, 2023, we sua sponte dismissed appellant’s appeal, finding that

it had been untimely filed. App.R. 4(A)(1) requires a party seeking to appeal a trial

court’s judgment to file their notice of appeal within 30 days of that entry. We found that

the trial court’s December 22, 2022 amendment of its December 20, 2022 judgment entry

was a nullity as “[a] trial court has no authority to vacate its own final orders sua sponte.”

Because we found the December 22, 2022 amended judgment to be a nullity, we

determined that appellant’s appeal was due not more than 30 days after the trial court’s

original December 20, 2022 judgment entry. Appellant’s notice of appeal was filed on

the 31st day after that judgment, so we dismissed his appeal on March 2, 2023.

2. {¶ 6} The next day, appellant filed a motion seeking reconsideration of our

decision dismissing his appeal, arguing that we committed obvious error when we failed

to consider the trial court’s jurisdiction to amend its own judgment to correct a clerical

error pursuant to Civ.R. 60(A). Specifically, appellant contended that the December 22,

2022 judgment entry corrected a “clerical mistake appearing at page 18 of the original

entry which ordered [appellee] to pay to [appellant] spousal support for three years,” and

therefore the December 22, 2022 judgment entry was not a nullity and his appeal was

timely filed.

{¶ 7} We granted appellant’s motion, explaining that appellant’s notice of appeal

may have been timely filed if the December 22, 2022 amended judgment entry corrected

a clerical error in the December 20, 2022 judgment entry and appellant asserted an

assignment of error involving the correction. Daniels-Rodgers v. Rodgers, 2015-Ohio-

1974, ¶ 15 (10th Dist.). Accordingly, we held that we could not determine whether

appellant’s brief was timely filed until we received and reviewed the entire record and the

parties’ briefs.

{¶ 8} Appellant filed his merit brief in support of his appeal on December 26,

2023 asserting a single assignment of error:

The trial court abused its discretion to the prejudice of appellant when dividing the

marital estate.

Appellant’s sole argument in support of his assignment of error is that the trial court

abused its discretion in awarding the Directions Credit Union account to appellee as her

3. separate property. Appellant’s sole assignment of error contains no arguments regarding

the award of spousal support.

II. Law and Analysis

{¶ 9} Pursuant to App.R. 4(A)(1), “a party who wishes to appeal from an order

that is final upon its entry shall file the notice of appeal required by App.R. 3 within 30

days of that entry.” The time requirement for filing a notice of appeal is jurisdictional in

nature, and may not be enlarged by an appellate court. State ex rel. Pendell v. Adams

Cty. Bd. of Elections, 40 Ohio St.3d 58, 60 (1988).

{¶ 10} Here, appellant’s notice of appeal was not filed within the 30-day period

following the trial court’s December 20, 2022 judgment entry. Accordingly, the

timeliness of appellant’s notice of appeal turns on whether the December 22, 2022

amended judgment entry extended appellant’s time to file his notice of appeal.

{¶ 11} As we previously discussed in our order granting appellant’s motion for

reconsideration, the timeliness of appellant’s notice of appeal first depends on the

character of the mistake in the December 20, 2022 judgment entry corrected in the trial

court’s December 22, 2022 amended judgment entry. If the December 22nd amended

entry corrected a substantive mistake in the December 20th entry, then the December

22nd entry was a nullity, as the court can only correct a substantive mistake in an order

through the framework of Civ.R. 60(B). See, e.g., Sperry v. Hlutke, 19 Ohio App.3d 156,

158 (8th Dist.1984).

4. {¶ 12} If, however, the December 20th entry merely contained a clerical mistake,

then the trial court could correct the mistake in its December 22nd entry pursuant to

Civ.R. 60(A). But our analysis does not end here. A trial court’s correction of an error

pursuant to Civ.R. 60(A) does not ordinarily extend or reset the time to file an appeal

from the judgment being amended. See Matter of H.S., 2017-Ohio-457, ¶ 49 (4th Dist.),

citing State v. Bonnell, 2014-Ohio-3177; State v. Yeaples, 2009-Ohio-184, ¶ 15 (3d

Dist.); Daniels-Rodgers v. Rodgers, 2015-Ohio-1974, ¶ 12 (10th Dist.); Herb v. Loughlin,

2013-Ohio-5149, ¶ 12 (5th Dist.); Wells v. Wells, 2014-Ohio-4610, ¶ 18 (2d Dist.)

(holding that the trial court’s granting of appellee’s Civ.R. 60(A) motion to correct a

clerical error two months after the granting of final judgment did not grant appellant a

new timeline to appeal from the original judgment); Rutana v. Koulianos, 2020-Ohio-

6848, ¶ 26 (7th Dist.).

{¶ 13} The correction of a clerical error may only extend the time to file a notice

of appeal if the correction creates new rights, denies existing rights, or resolves some

genuine ambiguity. Daniels-Rodgers at ¶ 15. “In such cases, it is quite possible that a

party that is not aggrieved by the original (erroneous) version of the trial court’s

judgment would have no grounds to timely appeal it, but then find itself out of rule and

deprived of appeal when a clerically corrected (and now injurious) judgment is later

entered nunc pro tunc.” Id. Under this exception, therefore, appellant’s notice of appeal

must raise some issue that could not have been raised before the trial court issued a

5. corrected judgment entry. Id. The facts of this case do not fall into this narrow

exception.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Bonnell (Slip Opinion)
2014 Ohio 3177 (Ohio Supreme Court, 2014)
Herb v. Loughlin
2013 Ohio 5149 (Ohio Court of Appeals, 2013)
Wells v. Wells
2014 Ohio 4610 (Ohio Court of Appeals, 2014)
Sperry v. Hlutke
483 N.E.2d 870 (Ohio Court of Appeals, 1984)
State v. Yeaples
907 N.E.2d 333 (Ohio Court of Appeals, 2009)
In re H.S.
2017 Ohio 457 (Ohio Court of Appeals, 2017)
State ex rel. Pendell v. Adams County Board of Elections
531 N.E.2d 713 (Ohio Supreme Court, 1988)

Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 2569, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hall-v-hall-ohioctapp-2024.