Huntington Natl. Bank v. Rizzo

2019 Ohio 3994
CourtOhio Court of Appeals
DecidedSeptember 30, 2019
Docket2018-T-0065
StatusPublished

This text of 2019 Ohio 3994 (Huntington Natl. Bank v. Rizzo) 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
Huntington Natl. Bank v. Rizzo, 2019 Ohio 3994 (Ohio Ct. App. 2019).

Opinion

[Cite as Huntington Natl. Bank v. Rizzo, 2019-Ohio-3994.]

IN THE COURT OF APPEALS

ELEVENTH APPELLATE DISTRICT

TRUMBULL COUNTY, OHIO

THE HUNTINGTON NATIONAL BANK, : OPINION

Plaintiff-Appellee, : CASE NO. 2018-T-0065 - vs - :

BRIAN J. RIZZO, et al., :

Defendant-Appellant. :

Civil Appeal from the Trumbull County Court of Common Pleas, Case No. 2017 CV 00816.

Judgment: Affirmed.

Melissa Whalen and Matthew Adam Taulbee, Gerner & Kearns Co., LPA, 7900 Tanners Gate Lane, Florence, KY 41042 (For Plaintiff-Appellee).

Brian J. Rizzo, pro se, 867 Wilson Sharpsville Road, Cortland, OH 44410 (Defendant- Appellant).

THOMAS R. WRIGHT, P.J.

{¶1} Appellant, Brian J. Rizzo, appeals the judgment entry and decree in

foreclosure in favor of appellee, Huntington National Bank. He contends the trial court

erred in holding as a matter of law that he failed to establish the affirmative defense of

accord and satisfaction We affirm.

{¶2} In September 2010, appellant purchased a residence on Wilson-Sharpsville

Road in Cortland, Trumbull County, Ohio. In so doing, he executed a promissory note and a mortgage.

{¶3} In October 2016, appellant defaulted on the loan by not making a required

payment. Two months later, appellee sent appellant a letter stating its intent to accelerate

the debt and foreclose on the loan. The letter further states that appellant could avoid

these consequences by paying $3,052.16 by January 31, 2017.

{¶4} On January 23, 2017, appellant mailed a $450 money order to appellee.

The money order states: “Full Satisfaction of Claim.” Ten days later, on February 3, 2017,

appellee via letter returned the check to appellant as insufficient.

{¶5} On February 15, 2017, appellee sent appellant an offer to modify the terms

of the promissory note by lowering the amount of his monthly payment to $839.32. Two

days later, appellant mailed a second money order to appellee, again in the amount of

$450. Like the first money order, the second states “Full Satisfaction of Claim.”

{¶6} Upon receipt, appellee put the second money order in a suspense account

awaiting additional funds. None were received and appellee rescinded its offer to modify

and returned the $450 placed in the suspense account to appellant on April 7, 2017.

{¶7} In May 2017, appellee filed the underlying foreclosure case.

{¶8} Appellant represented himself throughout the foreclosure case. In moving

to dismiss appellee’s complaint, he denied that he owed anything and asserted multiple

defenses under Civ.R. 12(B). However, he did not raise the affirmative defense of accord

and satisfaction in his initial pleadings.

{¶9} Ultimately, appellee moved for summary judgment on its claims, and

presented unchallenged documentation establishing appellant’s default.

{¶10} Appellant did not file a memorandum in opposition or challenge any of

2 appellee’s assertions in its motion. Instead, appellant submitted a competing motion for

summary judgment arguing accord and satisfaction. In support, he attached to his motion

copies of the previously discussed money orders and letters.

{¶11} After appellee responded to appellant’s motion, the trial court granted

summary judgment in favor of appellee on the entire foreclosure complaint, the accord

and satisfaction defense, and appellant’s counterclaim.

{¶12} Three weeks later, the trial court entered judgment in appellee’s favor for

$108,748.96, and ordered that the property be sold by the Trumbull County Sheriff unless

appellant exercised his right of redemption within five days.

{¶13} In appealing both entries, appellant asserts four assignments:

{¶14} “[1.] The trial court erred in granting judgment to plaintiff-appellee on its

claim for breach of contract because there was an accord and satisfaction by statute and

common law.

{¶15} “[2.] The trial court erred in failing to recognize defendant’s affirmative

defense that plaintiff breached the agreement in many material respects which is an

affirmative defense to plaintiff’s breach of contract claim and discharges defendant’s

obligation to make the remaining payments under the agreement.

{¶16} “[3.] The trial court erred because its findings were against the manifest

weight of the evidence in holding for plaintiff on its claim and failing to apply defendant’s

affirmative defenses to plaintiff’s claim.

{¶17} “[4.] Appellant was denied due process when the trial court passed

retrospective laws interfering in appellant’s right to contract violating the United States

Constitution and Article 2, Section 28.”

3 {¶18} Since appellant’s first two assignments are closely related, they will be

addressed together. He contends the trial court erred in finding his evidentiary materials

insufficient to establish accord and satisfaction.

{¶19} “‘An accord and satisfaction is a method of discharging a contract or settling

a cause of action arising either from a contract or tort, by substituting for such contract or

cause of action an agreement for the satisfaction thereof an execution of such substituted

agreement.’ Kirk Williams Co., Inc. v. Six Industries, Inc., 11 Ohio App.3d 152, 153, 463

N.E.2d 1266 (2d Dist.1983), citing Chillicothe Hosp. v. Garrett, 26 Ohio App.2d 277, 271

N.E.2d 313 (1st Dist.1971). Further, ‘[a]n accord is a contract under which an obligee

promises to accept a stated performance in satisfaction of the obligor’s existing duty.

Performance of the accord discharges the original duty.’ Restatement of the Law 2d,

Contracts, Section 281(1), at 381-382 (1981).” Smith v. E.S. Wagner Co., 2016-Ohio-

8096, 74 N.E.3d 963, ¶ 65 (3rd Dist.).

{¶20} R.C. 1303.40 governs accord and satisfaction through submission of a

written instrument:

{¶21} “If a person against whom a claim is asserted proves that that person in

good faith tendered an instrument to the claimant as full satisfaction of the claim, that the

amount of the claim was unliquidated or subject to a bona fide dispute, and that the

claimant obtained payment of the instrument, all of the following apply:

{¶22} “(A) Unless division (B) of this section applies, the claim is discharged if the

person against whom the claim is asserted proves that the instrument or an

accompanying written communication contained a conspicuous statement to the effect

that the instrument was tendered as full satisfaction of the claim.

4 {¶23} “(B) Subject to division (C) of this section, a claim is not discharged under

division (A) of this section if either of the following applies:

{¶24} “* * *

{¶25} “(2) The claimant, whether or not an organization, proves that within

ninety days after payment of the instrument, the claimant tendered repayment of

the amount of the instrument to the person against whom the claim is asserted.

* * *.” (Emphasis added.)

{¶26} Applying accord and satisfaction, the Ohio Supreme Court held:

{¶27} “1. When an accord and satisfaction is pled by the defendant as an

affirmative defense, the court’s analysis must be divided into three distinct inquiries. First,

the defendant must show that the parties went through a process of offer and

acceptance–an accord. Second, the accord must have been carried out–a satisfaction.

Third, if there was an accord and satisfaction, it must have been supported by

consideration.

{¶28} “2.

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Chillicothe Hospital v. Garrett
271 N.E.2d 313 (Ohio Court of Appeals, 1971)
Kirk Williams Co. v. Six Industries, Inc.
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611 N.E.2d 794 (Ohio Supreme Court, 1993)
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2019 Ohio 3994, Counsel Stack Legal Research, https://law.counselstack.com/opinion/huntington-natl-bank-v-rizzo-ohioctapp-2019.