Helfrich v. Hopson

Ohio Court of Appeals·Decided July 13, 2026·No. 2025-CA-00097·Published

Opinion

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.).

{¶20} The standard for manifest-weight review in civil cases is the same as in criminal cases. Eastley v. Volkman, 2012-Ohio-2179, ¶ 17. “In determining whether a [judgment] is against the manifest weight of the evidence, the court of appeals functions as the ‘thirteenth juror,’ and, after ‘reviewing the entire record, weighs the evidence and all reasonable inferences, considers the credibility of witnesses and determines whether in resolving conflicts in the evidence, the [trier of fact] clearly lost its way and created such a manifest miscarriage of justice that the [judgment] must be overturned and a new trial ordered.” State v. Hane, 2025- Ohio-120, ¶ 20 (5th Dist.), quoting State v. Thompkins, 78 Ohio St.3d 380, 387 (1997).

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