Hnat v. Eclipse Awning Sys., L.L.C.

Ohio Court of Appeals·Decided August 28, 2026·No. 30720·Published

Opinion

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT MONTGOMERY COUNTY

JILL HNAT, AS EXECUTRIX OF THE : ESTATE OF MICHAEL HNAT : C.A. No. 30720 :

Appellant : Trial Court Case No. 2025 CV 00050 :

v. : (Civil Appeal from Common Pleas : Court)

ECLIPSE AWNING SYSTEMS LLC :

: FINAL JUDGMENT ENTRY & Appellee : OPINION

...........

Pursuant to the opinion of this court rendered on August 28, 2026, the judgment of the trial court is affirmed.

Costs to be paid as stated in App.R. 24.

Pursuant to Ohio App.R. 30(A), the clerk of the court of appeals shall immediately send a copy of the court’s ruling to each party and note that action on the docket. Additionally, pursuant to App.R. 27, the clerk of the court of appeals shall send a certified copy of this judgment, which constitutes a mandate, to the clerk of the trial court and note the service on the appellate docket.

For the court,

CHRISTOPHER B. EPLEY, JUDGE HANSEMAN, J., concurs in judgment only.

HUFFMAN, J., dissents.

OPINION

MONTGOMERY C.A. No. 30720

LOUIS C. SCHNEIDER, Attorney for Appellant JENNIFER L. WILSON and SYDNEY M. BRAVERMAN, Attorneys for Appellee

EPLEY, J.

{¶ 1} Jill Hnat, as Executrix of the Estate of Michael Hnat, appeals from the Montgomery County Common Pleas Court’s judgment sustaining the motion for judgment on the pleadings of Eclipse Awning Systems, LLC (“Eclipse”). Hnat asserts that the trial court erred by finding that the awning at issue is a product, rather than a fixture, making her claims subject to the ten-year statute of repose. For the following reasons, the trial court’s judgment is affirmed.

I. Facts and Procedural History

{¶ 2} On August 5, 2023, the decedent, Michael Hnat, was attempting to remove a retractable awning system from his home when the retractable mechanism detached, striking him and causing him to fall. Michael died because of his injuries. A prior owner of the home had ordered the awning system from Eclipse in July 2007, and it was shipped and delivered shortly thereafter.

{¶ 3} On January 3, 2025, Hnat filed a complaint, bringing claims for negligence and wrongful death against Eclipse. The complaint asserted that Eclipse knowingly sold the defective awning system and failed to warn consumers of the defects. On March 4, 2025, Hnat filed an amended complaint, which included the same claims for relief, but she specifically asserted that the retractable awning system was a “fixture” and therefore not included in Ohio’s product liability statute. See Amended Complaint, ¶ 2-3. Hnat further asserted that because the awning system was a fixture, rather than a product, her claims for

personal injury and death related to the awning system were not subject to Ohio’s ten-year statute of repose for product liability claims. In both complaints, Hnat sought punitive damages.

{¶ 4} On April 7, 2025, Eclipse filed a motion for judgment on the pleadings as to Hnat’s claims. Eclipse asserted that the awning system was a “product” as defined by R.C. 2307.71(A)(12)(a) and that Hnat’s claims were therefore barred by the ten-year statute of repose. Eclipse contended that the awning system was sold through a bill of sale to the original purchaser in July 2007, the awning was not required to use the patio, and the awning system was removable and could be reinstalled on another area of the home. Eclipse further asserted that notwithstanding Hnat’s contention that the awning system was a fixture, the installation of the awning system constituted a real property improvement, and on that basis, Hnat’s claims were still barred by the statute of repose of R.C. 2305.131(A)(1).

{¶ 5} On November 17, 2025, the trial court sustained Eclipse’s motion for judgment on the pleadings. The trial court concluded that the awning system constituted a “product” under R.C. 2307.71(A)(12)(a) because “it was capable of delivery itself as an assembled whole or as a component; it was supplied for introduction into commerce; and it was intended for sale to persons for commercial or personal use.” Final Judgment, p. 5. The trial court further concluded that because Hnat’s claims for negligence and wrongful death were “essentially product liability claims,” they were subject to the ten-year statute of repose, which limits the accrual of such claims to no later than ten years from the date of the product’s delivery to the purchaser. The trial court noted that the attempted removal of the awning system that led to Michael Hnat’s injury and death occurred approximately sixteen years after the awning system’s date of delivery, and the claims were therefore time barred.

{¶ 6} In addition, the trial court found that the ten-year statute of repose set forth in R.C. 2125.02(F)(2)(a) would also bar Hnat’s wrongful death claim. This statute states that “[n]o cause of action for wrongful death involving a product liability claim shall accrue against the manufacturer or supplier of a product later than ten years from the date that the product was delivered to its first purchaser or first lessee who was not engaged in a business in which the product was used as a component in the production, construction, creation, assembly, or rebuilding of another product.” Because more than ten years had passed since the awning system was delivered to the prior homeowner, the trial court concluded that this statute also precluded Hnat from bringing the underlying claims against Eclipse.

{¶ 7} As for Eclipse’s assertion that Hnat’s claims were also barred by the statute of repose of R.C. 2305.131(A)(1), the trial court determined that this statute was irrelevant to Hnat’s claims. The trial court noted that this statute pertains to an “improvement to real property,” which is “a permanent addition, enlargement, or alteration that, had it been constructed at the same time as the building or structure, would have been considered part of the building or structure,” and the awning system was not a permanent addition to Michael Hnat’s home. Accordingly, the trial court concluded that Hnat’s claims had not “arisen out of a defective and unsafe condition of an improvement to real property that would trigger the statute of repose.”

{¶ 8} Considering Hnat’s claim for punitive damages, the trial court noted that Hnat could not recover punitive damages without first obtaining an award of compensatory damages. Because the trial court found that Hnat’s claims for negligence and wrongful death were barred by the product liability statute of repose, the court also found that Hnat could not maintain an independent claim for punitive damages. The trial court granted Eclipse’s motion for judgment on the pleadings in its entirety.

{¶ 9} Hnat now appeals the trial court’s judgment. She raises one assignment of error.

II. Appellate Review

{¶ 10} In Hnat’s assignment of error, she argues that the trial court erred when it determined that the awning system was a product, not a fixture. She further asserts that, because the awning system was a fixture, the statute of repose in R.C. 2125.02(F)(2)(a) is irrelevant. Rather, according to Hnat, her claims are subject to the two-year statute of limitations set forth in R.C. 2125.02(F)(1), which began accruing at the time of Michael Hnat’s death.

{¶ 11} We review a trial court’s decision on a motion for judgment on the pleadings de novo because these motions present only questions of law. Newman v. University of Dayton, 2021-Ohio-1609, ¶ 21 (2d Dist.). Entry of judgment pursuant to Civ.R. 12(C) is only appropriate where the court construes the material allegations in the complaint in favor of the non-moving party as true and finds that the plaintiff could prove no set of facts in support of its claim that would entitle it to relief. Id.

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Hnat v. Eclipse Awning Sys., L.L.C., (Ohio Ct. App. 2026).

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