In re Estate of Parks

2024 Ohio 1841
CourtOhio Court of Appeals
DecidedMay 13, 2024
DocketCA2023-10-081
StatusPublished
Cited by1 cases

This text of 2024 Ohio 1841 (In re Estate of Parks) 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
In re Estate of Parks, 2024 Ohio 1841 (Ohio Ct. App. 2024).

Opinion

[Cite as In re Estate of Parks, 2024-Ohio-1841.]

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO

WARREN COUNTY

IN RE: :

THE ESTATE OF LAWRENCE R. : CASE NO. CA2023-10-081 PARKS : OPINION 5/13/2024 :

:

APPEAL FROM WARREN COUNTY COURT OF COMMON PLEAS PROBATE DIVISION Case No. PE 20221301

Pro Seniors, Inc., and Tracye T. Hill and Miriam H. Sheline, for appellant.

Rolf Goffman Martin Land LLP, and David S. Brown and Michael S. Kearns, for appellee.

S. POWELL, P.J.

{¶ 1} Toni J. Parks appeals the decision and entry of the Warren County Probate

Court granting Chesterwood Nursing Care, Ltd.'s ("Chesterwood") motion for relief from

judgment. For the reasons outlined below, we affirm the probate court.

Factual and Procedural Background

{¶ 2} Lawrence Parks became a resident of Chesterwood in January of 2021. He

remained there until October 22, 2021. It is unclear from the record why exactly Lawrence Warren CA2023-10-081

left the facility. However, Lawrence was later hospitalized after a fall and passed away

on November 17, 2021. He was survived by Toni Parks, his spouse. At the time of his

death, Lawrence owed Chesterwood an outstanding balance of $72,882.74 for the

services and care provided by Chesterwood. Unaware that Lawrence had passed away,

Chesterwood commenced suit against Lawrence in the Warren County Common Pleas

Court to recover the amount owed. After learning of Lawrence's death, Chesterwood

dismissed the suit.

{¶ 3} As of April 28, 2022, over five months after Lawrence's death, no estate had

been opened for him. On that day, attorney W. Cory Phillips filed an application in the

Warren County Probate Court to be appointed special administrator of Lawrence's estate.

The application provided that it was made for the purpose of allowing creditors' claims to

be timely presented and to preserve Chesterwood's claim against Lawrence's estate.

Without a hearing or notice to Mrs. Parks, the probate court appointed Phillips special

administrator of Lawrence's estate in April of 2022.

{¶ 4} Phillips subsequently filed a notice that Chesterwood had presented to him

its claim against Lawrence's estate in the sum of $72,222.74. Phillips also discovered

that Lawrence's real property was not an estate asset and had transferred to Mrs. Parks

upon Lawrence's death. Aware of no other estate assets, Phillips filed a motion to

terminate the estate. The estate was closed, and Phillips was discharged as special

administrator in September of 2022.

{¶ 5} Two days prior to the probate court's order closing the estate, Chesterwood

filed a separate claim in the general division of the Warren County Common Pleas Court

against Mrs. Parks for the sum Lawrence had owed Chesterwood.

{¶ 6} In January of 2023, over one year after Lawrence's death and four months

after the court's closure of his estate, Mrs. Parks filed a motion in probate court to reopen

-2- Warren CA2023-10-081

Lawrence's estate and to be appointed executor of the estate under Lawrence's will. The

motion also requested the probate court vacate, as void ab initio,1 Phillips' appointment

as special administrator because Mrs. Parks was not provided notice of Phillip's

application for appointment as special administrator and no hearing was held on the

matter. Mrs. Parks' motion to reopen the estate was served on Phillips via email in

November of 2022 and in January of 2023.

{¶ 7} Mrs. Parks motion to reopen the estate and the forms that accompanied it

contained limited reference of the action pending against her in the general division

related to Lawrence's estate. Neither Chesterwood nor Phillips responded to Mrs. Parks'

motion. On January 30, 2023, the probate court granted Mrs. Parks' motion to reopen

the estate and held that Phillips' prior appointment as special administrator was revoked

and vacated as void ab initio (the "January Order").

{¶ 8} After the estate was reopened, no action was taken until June of 2023 when

the probate court issued a citation for a past-due inventory of the estate. Mrs. Parks filed

an inventory showing $580 of assets in Lawrence's estate. In September of 2023, the

court also issued a citation for a past-due account.

{¶ 9} That same month, nearly eight months after the January Order,

Chesterwood filed a motion in the probate court for relief from the January Order.

Chesterwood claimed that it only became aware the probate court had ruled Phillip's

appointment as special administrator was void ab initio from Mrs. Parks' motion for

summary judgment filed in the related action pending in the general division.

Chesterwood argued that the trial court should grant relief because vacation of Phillips

appointment as special administrator would also vacate Chesterwood's timely

1. Void means, "To render of no validity or effect * * *." VOID, Black's Law Dictionary (11th ed. 2019). Ab initio means, "From the beginning * * *." AB INITIO, Black's Law Dictionary (11th ed. 2019). -3- Warren CA2023-10-081

presentment of its claim against Lawrence's estate and prevent Chesterwood from

pursuing its claim against Mrs. Parks in the general division.

{¶ 10} On October 3, 2023, the probate court granted Chesterwood's motion for

relief from judgment (the "October Order"). The October Order stated the court's prior

entry revoking Phillips' appointment was made without an awareness of the action

pending in the general division and that "vacation of Phillips' appointment ab initio would

nullify Chesterwood's claim" against Lawrence's estate. Mrs. Parks now appeals that

order.

{¶ 11} Mrs. Parks raises two assignments of error that can be addressed together.

{¶ 12} Assignment of Error No. 1:

{¶ 13} THE PROBATE COURT ABUSED ITS DISCRETION AND ERRED WHEN

IT VACATED ITS PRIOR ORDER AND GRANTED APPELLEE'S MOTION FOR

RELIEF PROM JUDGMNENT.

{¶ 14} Assignment of Error No. 2:

{¶ 15} THE PROBATE COURT ERRED IN REINSTATING ITS ENTRY

APPOINTING PHILLIPS SPECIAL ADMINISTRATOR AS SAID ENTRY IS VOID AB

INITIO.

{¶ 16} Mrs. Parks argues on appeal that Phillips' appointment as special

administrator was void ab initio and thus Chesterwood lacks a meritorious claim or

defense entitling it to relief under Civ.R. 60(B). Mrs. Parks also asserts Chesterwood had

notice of her motion to declare Phillips' appointment void ab initio and that Chesterwood

failed to file its motion within a reasonable amount of time. Thus, according to Mrs. Parks,

Chesterwood cannot demonstrate extraordinary circumstances entitling it to relief under

Civ.R. 60(B).

{¶ 17} Mrs. Park further contends that Phillips' appointment as special

-4- Warren CA2023-10-081

administrator of Lawrence's estate was void ab initio because notice of his application to

be appointed was never sent out and a hearing on the matter was not held. Mrs. Parks

claims this violated her due process rights. As a result, she claims the trial court had no

ability to reinstate Phillips' appointment.

{¶ 18} Within these assignments of error, Ms. Parks also argues that

Chesterwood's Civ.R. 60(B) motion was an inappropriate substitute for a direct appeal of

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2024 Ohio 1841, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-estate-of-parks-ohioctapp-2024.