Hunt v. Arboretum Home Owners Assn.

2020 Ohio 4947
CourtOhio Court of Appeals
DecidedOctober 19, 2020
DocketCA2020-02-025
StatusPublished
Cited by4 cases

This text of 2020 Ohio 4947 (Hunt v. Arboretum Home Owners Assn.) 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
Hunt v. Arboretum Home Owners Assn., 2020 Ohio 4947 (Ohio Ct. App. 2020).

Opinion

[Cite as Hunt v. Arboretum Home Owners Assn., 2020-Ohio-4947.]

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO

BUTLER COUNTY

DERICK W. HUNT, :

Appellee, : CASE NO. CA2020-02-025

: OPINION - vs - 10/19/2020 :

THE ARBORETUM HOME OWNERS : ASSOCIATION, INC., : Appellant.

CIVIL APPEAL FROM BUTLER COUNTY COURT OF COMMON PLEAS Case No. CV2019-11-2284

David B. Brewer, 110 North Third Street, Hamilton, Ohio 45011, for appellant

Jack F. Grove, 1251 Nilles Road, Suite 10, Fairfield, Ohio 45014 and Joseph L. Beyke, 8561 S. Mason-Montgomery Road, Suite 28, Mason, Ohio 45040, for appellee

PIPER, J.

{¶1} Appellant, The Arboretum Homeowners Association, Inc. ("Arboretum HOA")

appeals a decision of the Butler County Court of Common Pleas granting default judgment

to appellee, Derick Hunt, denying its motion for relief from judgment, and denying its motion Butler CA2020-02-025

for a temporary restraining order and preliminary injunction.1

{¶2} Hunt filed a complaint for breach of contract and a declaratory judgment action

against Arboretum HOA and a former president after Arboretum HOA denied his petition to

add a detached garage to his property. Arboretum HOA denied Hunt's request based upon

a limitation in the community's declaration that no outbuilding, temporary or permanent, may

be erected or used on lots in the community.

{¶3} Hunt sent his complaint to Matthew Roesch, Arboretum HOA's previously

"registered agent," and listed in the complaint Arboretum HOA's president as Charles

Henson. Roesch once represented Henson and had been appointed statutory agent for

Arboretum HOA. However, Roesch did not sign the certified mail receipt because he had

since moved to Colorado and no longer practices law in Ohio. The law firm Roesch was

previously associated with forwarded the complaint to Roesch in Colorado. Roesch

emailed Hunt's counsel to explain his relocation to Colorado, as well as the fact that Charles

Henson had passed away and was thus no longer Arboretum HOA's president.

{¶4} Within the email, Roesch indicated that he had relocated to Colorado, no

longer practiced in Ohio, and was unaware of how to contact Arboretum HOA given that his

client had passed away. Roesch requested assistance in forwarding the complaint to

Arboretum HOA, but Hunt's counsel did not reply to the email. Despite the circumstances

being explained to Hunt, Hunt sought default judgment without taking further steps to

perfect service.

{¶5} The trial court granted Hunt's motion for default judgment and declared Hunt's

right to build the detached garage on his property. Nine days later, Arboretum HOA moved

the trial court for relief from judgment. It included an affidavit from Matthew Roesch, as well

1. Pursuant to Loc.R. 6(A), we sua sponte remove this case from the accelerated calendar for the purpose of issuing this opinion.

-2- Butler CA2020-02-025

as its current president indicating that his first knowledge of Hunt's suit was three days prior.

Arboretum HOA's president also averred that Arboretum HOA was unaware of Roesch's

relocation and was unaware of the need to appoint a new statutory agent. Even so, the trial

court denied Arboretum HOA's motion for relief from judgment. Arboretum HOA now

appeals the trial court's decision, raising two assignments of error. We will address the

assignments of error together for ease of discussion.

{¶6} Assignment of Error No. 1:

{¶7} THE COMMON PLEAS COURT ERRED IN GRANTING DEFAULT

JUDGMENT AND IN RENDERING DECLARATORY JUDGMENT CONCERNING

CONTRACT RIGHTS, WHEN IT FAILED TO CONDUCT AN EVIDENTIARY HEARING,

BECAUSE THE COMPLAINT DID NOT HAVE THE OPERATIVE WRITTEN

INSTRUMENTS ATTACHED AND THE COURT FAILED TO CONSIDER THE EXPRESS

CONTRACT LANGUAGE AND THE TRANSACTION SETTING.

{¶8} Assignment of Error No. 2:

{¶9} THE COMMON PLEAS COURT ERRED IN OVERRULING ARBORETUM

HOA'S MOTION FOR RELIEF FROM JUDGMENT.

{¶10} Arboretum HOA argues in its two assignments of error that the trial court erred

in granting default judgment, rendering declaratory judgment, and in denying Arboretum

{¶11} A judgment rendered in the absence of personal jurisdiction over a defendant

is void. Motorists Mut. Ins. Co. v. Roberts, 12th Dist. Warren No. CA2013-09-089, 2014-

Ohio-1893, ¶ 30. A trial court lacks personal jurisdiction over a defendant if effective service

of process has not been made on the defendant and the defendant has not voluntarily

appeared in the case or waived service. Lauver v. Ohio Valley Selective Harvesting, LLC,

12th Dist. Clermont No. CA2016-11-076, 2017-Ohio-5777, ¶ 15. We review matters of

-3- Butler CA2020-02-025

personal jurisdiction de novo. Start Skydiving, LLC v. Wiese, 12th Dist. Butler No. CA2017-

04-042, 2017-Ohio-7020.

{¶12} For service of process to be effective, it must comport with the requirements

of due process. Akron-Canton Regional Airport Auth. v. Swinehart, 62 Ohio St.2d 403,

(1980), syllabus. Due process requires that service of process be accomplished in a

manner reasonably calculated, under all the circumstances, to apprise interested parties of

the pendency of the action and afford them an opportunity to present their objections. Id.

{¶13} According to Civ.R. 4.2(F), service upon a corporation may occur "by serving

the agent authorized by appointment or by law to receive service of process; or by serving

the corporation at any of its usual places of business by a method authorized under Civ.R.

4.1 (A)(1); or by serving an officer or a managing or general agent of the corporation."

Civ.R. 4.6(A) provides that "all process may be served anywhere in this state and, when

authorized by law or these rules, may be served outside this state."

{¶14} R.C. 1702.06(A)(1) requires that an agent who is a natural person be a

resident of Ohio and subsection (D) requires the corporation designate a different agent if

the original "removes" from Ohio. Should a corporation fail to properly maintain an agent,

R.C. 1702.06(H)(2) provides that the party requesting service may file an affidavit with the

Secretary of State explaining the circumstances and demonstrating attempts to determine

the corporation's most recent address. Once the criteria is met for the affidavit, and the

affidavit is filed, service may be obtained upon the Secretary of State.

{¶15} Where a plaintiff follows the Rules of Civil Procedure regarding service of

process, a rebuttable presumption of proper service arises. Lauver, 2017-Ohio-5777.

However, this presumption can be rebutted where a defendant presents sufficient evidence

demonstrating that service was not accomplished. Gaston v. Medina Cty. Bd. of Revision,

133 Ohio St.3d 18, 2012-Ohio-3872. A failure of service may occur where the defendant

-4- Butler CA2020-02-025

does not receive the summons and complaint, even though the plaintiff attempted to comply

with the civil rules with service made at an address where the plaintiff might reasonably

anticipate that the defendant would receive it. Lauver.

{¶16} After reviewing the record, we find that proper service was never effectuated.

There is no dispute that Hunt complied with the rules of civil procedure in serving Roesch,

thus giving rise to a rebuttable presumption of proper service. However, and although

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2020 Ohio 4947 (Ohio Court of Appeals, 2020)

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2020 Ohio 4947, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hunt-v-arboretum-home-owners-assn-ohioctapp-2020.