Hazelwood Assn., Inc. v. Helfrich

2025 Ohio 2968
CourtOhio Court of Appeals
DecidedAugust 19, 2025
Docket24 CA 00095
StatusPublished

This text of 2025 Ohio 2968 (Hazelwood Assn., Inc. v. Helfrich) 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
Hazelwood Assn., Inc. v. Helfrich, 2025 Ohio 2968 (Ohio Ct. App. 2025).

Opinion

[Cite as Hazelwood Assn., Inc. v. Helfrich, 2025-Ohio-2968.]

COURT OF APPEALS LICKING COUNTY, OHIO FIFTH APPELLATE DISTRICT

HAZELWOOD ASSOCIATION, INC., : Case No. 24 CA 00095 : Plaintiff - Appellee : Opinion & Judgment Entry : -vs- : Appeal from the Licking County : Municipal Court, JAMES HELFRICH, : Case No. 08 CVI 02753 : Defendant - Appellant : Judgment: Affirmed

Date of Judgment: August 19, 2025

Before: William B. Hoffman, Andrew J. King, and David M. Gormley, Judges

Appearances: David A. Dye for Plaintiff-Appellee; James C. Helfrich for Defendant- Appellant

Gormley, J.

{¶1} Appellant James Helfrich is challenging the trial court’s decision to revive a

dormant judgment against him. He raises several arguments here, asserting that the trial

court failed to consider his defenses and evidence, considered some evidence that should

not have been considered, and issued a judgment that was against the manifest weight

of the evidence. For the reasons that follow, we affirm the judgment of the trial court

reviving the dormant judgment.

The Key Facts

{¶2} The parties’ lengthy financial dispute began 17 years ago when plaintiff

Hazelwood Association — a homeowners’ association for a residential subdivision in

Pataskala, Ohio — sued Helfrich to collect unpaid dues, attorney’s fees, and court costs. Hazelwood won that suit, and the trial court issued a judgment against Helfrich in 2009

for $778.38 plus interest. When Helfrich appealed, this court affirmed. See Hazelwood

Assn., Inc. v. Helfrich, 2010-Ohio-2871 (5th Dist.).

{¶3} Hazelwood then tried to collect the judgment by attaching liens to Helfrich’s

property and by seeking to garnish from local banks any available funds belonging to

Helfrich. The last of those garnishment actions — all of which appear to have been

unsuccessful — was filed by Hazelwood in 2014. Five years after that, the 2009 judgment

— in accordance with R.C. 2329.07(B) — became dormant.

{¶4} Next, in 2020, Hazelwood filed a new lawsuit against Helfrich to recover

unpaid homeowners’ association dues and other fees. In that new complaint, Hazelwood

sought the unpaid dormant judgment from 2009 as well as additional dues and fees that

Hazelwood claimed were owed by Helfrich. That case ping-ponged between two different

trial courts and this court, with the upshot being that the case was ultimately dismissed

because of what appear to have been some missteps on the part of Hazelwood. See

Hazelwood Assn., Inc. v. Helfrich, 2022-Ohio-174 (5th Dist.).

{¶5} Then, in 2024, Hazelwood asked the trial court in this case to revive the

dormant 2009 judgment. The trial court granted that request, and Helfrich now appeals,

raising thirteen assignments of error.

The Dismissal of the 2020 Action Does Not Bar Revival of the 2009 Judgment

{¶6} We begin by addressing Helfrich’s argument that the dismissal of the 2020

action precludes Hazelwood from reviving the judgment that it obtained in 2009. Helfrich

contends that because Hazelwood included the amount owed on the 2009 judgment in the complaint that it filed in 2020, the 2009 judgment was dismissed when the 2020 action

was dismissed.

{¶7} The doctrine of res judicata or claim preclusion bars a party from relitigating

a claim that has already been decided on the merits in a final and appealable order. AJZ’s

Hauling, L.L.C. v. TruNorth Warranty Programs of North America, 2023-Ohio-3097, ¶ 15.

“Res judicata ensures the finality of decisions.” Id. Both parties in this case agree that

Hazelwood obtained a judgment in its favor in the 2009 case, and the parties agree, too,

that the order granting that judgment was final and appealable. Indeed, this court affirmed

that judgment in 2010.

{¶8} Any attempt — by either party — to relitigate the claim that was resolved in

the 2009 case is barred by the doctrine of claim preclusion. See O’Nesti v. DeBartolo

Realty Corp., 2007-Ohio-1102, ¶ 6 (“Claim preclusion prevents subsequent actions, by

the same parties or their privies, based upon any claim arising out of a transaction that

was the subject matter of a previous action”); In re Hufford, 460 B.R. 172, 179

(Bankr.N.D.Ohio 2011), quoting 46 Am.Jur.2d, Judgments, § 451 (now § 430 in the May

2025 update) (“when a valid and final personal judgment is rendered in favor of the

plaintiff, . . . the plaintiff cannot maintain a subsequent action on any part of the original

claim, because the doctrine of merger operates to extinguish a cause of action on which

a judgment is based and bars a subsequent action for the same cause”).

{¶9} When Hazelwood filed the 2020 lawsuit, it sought for the second time some

amounts that Helfrich had been ordered to pay to Hazelwood under the 2009 judgment.

Had a trial court reached the merits of Hazelwood’s 2020 complaint, that court would have

— under the doctrine of merger that is embodied in the concept of claim preclusion — dismissed the parts of Hazelwood’s 2020 claim for relief that had been litigated and

decided in the 2009 judgment. See Whitehead v. Gen. Tel. Co., 20 Ohio St.2d 108, 112

(1969) (“If the plaintiff in the prior action is successful, . . . that . . . plaintiff cannot recover

again on the same cause of action”).

{¶10} The doctrine of claim preclusion barred Hazelwood from trying to win a new

judgment in 2020 on the same issue addressed by the first judgment in 2009, but that

doctrine in no way limits Hazelwood’s efforts to collect on that earlier judgment.

Relitigation of the same issue is barred; collection of the original judgment is not.

Hazelwood’s fruitless filing of a new lawsuit in 2020 to relitigate the same claim on which

Hazelwood had already won a judgment in 2009 does not matter, just as the dismissal of

that lawsuit does not matter.

{¶11} We therefore find that Hazelwood’s motion to revive the 2009 dormant

judgment was not barred by the doctrine of claim preclusion.

The Tral Judge Properly Conducted the Judgment-Revival Hearing

{¶12} Helfrich argues that the trial judge was biased and should have recused,

and he claims, too, that the judge treated him unfairly because Helfrich had no lawyer.

We turn to those two arguments next.

Recusal Was Not Required

{¶13} We begin by addressing Helfrich’s argument that the trial judge should have

recused himself. Notably, Helfrich never asked the trial judge to step off the case and did

not ask the chief justice to remove him. “Generally, the proper avenue for redress when

a party believes that the trial judge is biased is the filing of an affidavit of [disqualification]

. . . with the Supreme Court of Ohio.” State v. Johnson, 140 Ohio App.3d 385, 391 (1st Dist. 2000), see also State v. Bacon, 2005-Ohio-6238, ¶ 66 (8th Dist.) (holding that an

appellate court lacks jurisdiction to void the judgment of a trial court in response to a claim

of judicial bias or prejudice because an aggrieved party’s exclusive remedy is to file an

affidavit of disqualification under R.C. 2701.03).

{¶14} Nonetheless, we have reviewed the record in this case, and we find no merit

in Helfrich’s argument that the trial judge was either biased or harbored a grudge.

“Judicial bias is demonstrated by ‘a hostile feeling or spirit of ill will or undue friendship or

favoritism toward one of the litigants or his attorney, with the formation of a fixed

anticipatory judgment on the part of the judge, as contradistinguished from an open state

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2025 Ohio 2968, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hazelwood-assn-inc-v-helfrich-ohioctapp-2025.