Helfrich v. Hopson

CourtOhio Court of Appeals
DecidedJuly 13, 2026
Docket2025-CA-00097
StatusPublished

This text of Helfrich v. Hopson (Helfrich v. Hopson) 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
Helfrich v. Hopson, (Ohio Ct. App. 2026).

Opinion

[Cite as Helfrich v. Hopson, 2026-Ohio-2683.]

IN THE OHIO COURT OF APPEALS FIFTH APPELLATE DISTRICT LICKING COUNTY, OHIO

JAMES HELFRICH Case No. 2025-CA-00097

Plaintiff - Appellant Opinion And Judgment Entry

-vs- Appeal from the Licking County Municipal Court, Case No. 25CVG00675 LONNIE HOPSON Judgment: Affirmed in part; Reversed in Defendant - Appellee part; Judgment Entered

Date of Judgment Entry: July 13, 2026

BEFORE: Craig R. Baldwin, Kevin W. Popham, and David M. Gormley, Judges

APPEARANCES: James Helfrich, Pro Se, Plaintiff-Appellant

OPINION

Popham, J.,

{¶1} Appellant/landlord James Helfrich appeals the judgment of the Licking

County Municipal Court denying portions of his request for damages in this landlord-tenant

action. Appellee is tenant Lonnie Hopson. For the reasons that follow, we affirm the

judgment in part, reverse it in part, and enter final judgment in favor of Helfrich.

Facts & Procedural History

{¶2} On June 5, 2019, Helfrich entered into a lease agreement with Hopson for the

rental of residential premises located at 159 South Township Road, Pataskala, Ohio. {¶3} Helfrich commenced a forcible entry and detainer action against Hopson

seeking restitution of the premises and monetary damages totaling $4,522.64. The trial court

granted restitution, and a writ of restitution was issued and executed in April of 2025. The

court subsequently scheduled a damages hearing for May 7, 2025, to address Helfrich’s claims

for unpaid rent and other damages.

{¶4} Before the hearing, on April 29, 2025, Helfrich filed a motion to supplement

his complaint with an itemized list of damages. The trial court did not rule on the motion.

Although the transcript reflects that the magistrate referred to the itemized list during the

hearing, Helfrich never moved to admit the document into evidence.

{¶5} Helfrich appeared at the May 7, 2025, hearing and testified in support of his

damages claims. He also presented the testimony of Randy Woolever and introduced the

following exhibits: Exhibit A, the rental agreement and addendum; Exhibit B, an unpaid

utility bill; and Exhibit C, undated photographs of the premises. Hopson did not appear for

the hearing.

{¶6} On September 10, 2025, the magistrate issued her decision – finding that

Hopson owed Helfrich $2,090 in unpaid rent, $300 in late fees under the rental agreement,

and $170.13 in unpaid utilities. The magistrate further found that while Helfrich incurred

expenses for cleaning the premises, hauling trash, and carpet replacement, and incurred

expenses to repair the premises in excess of normal wear and tear, he failed to present receipts

for these amounts. The magistrate also found that Hopson had paid a $995 security deposit.

{¶7} Based on these findings, the magistrate concluded that Helfrich established

damages of $2,560.13 for unpaid rent, late fees, and utilities. After applying a $995 setoff for

the security deposit, the magistrate awarded Helfrich $1,565.13. {¶8} On September 15, 2025, Helfrich filed objections to the magistrate’s decision.

He argued that the decision was contrary to the evidence and the law because his

uncontroverted testimony and photographic evidence established additional property

damages.

{¶9} On December 19, 2025, the trial court overruled Helfrich’s objections. The

court concluded that Helfrich failed to prove his entitlement to damages beyond those

awarded by the magistrate for unpaid rent, late fees, and utilities. The court entered judgment

in Helfrich’s favor in the amount of $1,565.13, together with court costs and post-judgment

interest at the statutory rate of eight percent per annum from the date of judgment.

{¶10} Helfrich appeals the December 19, 2025, judgment of the Licking County

Municipal Court, and assigns the following as error1:

{¶11} “I. DID THE TRIAL COURT ERR WHEN IT UPHELD A

MAGISTRATE’S DECISION THAT DENIED DAMAGES BECAUSE A RECEIPT

WAS NOT PRODUCED?”

{¶12} “II. IS THE TRIAL COURT’S DECISION AGAINST THE MANIFEST

WEIGHT OF THE EVIDENCE ON THE RECORD?”

{¶13} “III. IN A LANDLORD-TENANT DISPUTE OVER DAMAGES, IS THE

LANDLORD REQUIRED TO REPAIR OR CLEAN THE CLAIMS OR DAMAGES

(SIC) TO RECOVER HIS DAMAGES, I.E., WOULD THE LANDLORD BE ABLE TO

COLLECT ON HIS DAMAGES ON THE DIMINISHED VALUE OF THE PROPERTY

IF HE CHOOSES NOT TO EVEN CLEAN OR REPAIR IT.”

1 Assignments of error full capitalization in original. {¶14} “IV. DID THE MAGISTRATE AND THEREFORE THE TRIAL COURT

ERR WHEN IT CONDUCTED THE TRIAL AND REPEATEDLY TOLD HELFRICH

TO BE QUIET WHEN HE TRIED TO PRESENT HIS TESTIMONY.”

{¶15} “V. DID THE TRIAL COURT ERR WHEN IT FAILED TO TELL

HELFRICH THAT THEY WILL USE ANY RULES THEY WANT TO UNTIL HE

HUMBLES HIMSELF.”

Adding to the Record

{¶16} Throughout his briefing to this Court, Helfrich discusses cases other than the

one he has been permitted2 to appeal, and includes facts and documents from other cases. “A

reviewing court cannot add matter to the record before it that was not part of the trial court’s

proceedings, and then decide the appeal on the basis of the new matter.” State v. Hooks, 92

Ohio St.3d 83, 83 (2001); Doty v. Doty, 1980 Ohio App. LEXIS 12935, *4 (4th Dist. Feb. 28,

1980). New material and factual assertions contained in any brief in this Court may not be

considered. State v. Helfrich, 2019-Ohio-1785, ¶ 29 (5th Dist.). Therefore, we have disregarded

facts and documents that are outside the record.

I. & II.

{¶17} Helfrich’s first and second assignments of error are related, and will be

addressed together.

{¶18} As a preliminary matter, Helfrich repeatedly relies on what he refers to as

“Exhibit A,” an itemized list of damages. Although Helfrich attempted to supplement his

complaint with this list, the trial court entered final judgment without ruling on the motion to

supplement, thereby implicitly denying it. Byrd v. Frush, 2013-Ohio-3682, ¶ 40 (5th Dist.)

2 Appellant has been declared a Vexatious Litigator pursuant to R.C. 2323.52. (“when a trial court enters judgment prior to ruling on a pending motion, that motion is

considered to have been implicitly denied.”). Moreover, Helfrich never offered the itemized

list into evidence. Instead, Exhibit A admitted at trial was a copy of the rental agreement and

addendum. Exhibits B and C likewise did not include the itemized list. Accordingly,

Helfrich’s itemized list of damages is not properly before this Court. Hooks at 83.

{¶19} In his first assignment of error, Helfrich argues the magistrate, and therefore

the trial court, erred by indicating that receipts were required to prove damages. Helfrich is

correct that he is not required to provide receipts in order to prove damages and that testimony

alone may be sufficient to support a damage finding. That conclusion, however, does not

resolve the issue before us. “An award of damages in a landlord-tenant dispute is governed

by a manifest-weight-of-the-evidence review.” Hensel v. Childress, 2019-Ohio-3934, ¶ 24 (1st

Dist.). “The landlord bears the burden of submitting sufficient evidence to link the damages

to the tenant.” Estie Inv. Co. v. Braff, 2018-Ohio-4378, ¶ 25 (11th Dist.). Additionally, a

landlord may not recover for repairs attributable to reasonable wear and tear. Sotnyk v.

Guillenno, 2014-Ohio-3514, ¶5 (6th Dist.).

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Helfrich v. Hopson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/helfrich-v-hopson-ohioctapp-2026.