Jackson v. Cleveland

CourtOhio Court of Appeals
DecidedMay 28, 2026
Docket115619
StatusPublished

This text of Jackson v. Cleveland (Jackson v. Cleveland) 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
Jackson v. Cleveland, (Ohio Ct. App. 2026).

Opinion

[Cite as Jackson v. Cleveland, 2026-Ohio-1974.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

JERMAINE JACKSON, :

Plaintiff-Appellant, : No. 115619 v. :

CITY OF CLEVELAND, :

Defendant-Appellee. :

JOURNAL ENTRY AND OPINION

JUDGMENT: REVERSED AND REMANDED RELEASED AND JOURNALIZED: May 28, 2026

Civil Appeal from the Cuyahoga County Common Pleas Court Case No. CV-25-118796

Appearances:

Richard E. Hackerd, for appellant.

Mark D. Griffin, Cleveland Director of Law, James R. Russell, Jr., Chief Assistant Director of Law, and Affan Ali, Assistant Director of Law, for appellee.

MICHELLE J. SHEEHAN, A.J.:

{¶ 1} Plaintiff-appellant Jermaine Jackson appeals from the trial court’s

judgment granting the defendant-appellee City of Cleveland’s (“City”) motion for

judgment on the pleadings. Jackson raises two assignments of error for our review: 1. The trial court committed reversible error when it granted Defendant’s Motion for Judgment on the Pleadings.

2. The trial court committed reversible error when it denied Plaintiff- Appellant’s Motion for Extension of Time to respond to the Defendant’s Motion for Judgment on the Pleadings.

{¶ 2} After review, we reverse and remand. We conclude that the City is

not entitled to judgment on the pleadings based on the statute of limitations or

political-subdivision immunity at this stage of the proceedings. We therefore

sustain Jackson’s first assignment of error and find Jackson’s second assignment of

error to be moot.

I. Procedural History and Factual Background

{¶ 3} Jackson filed a complaint against the City on June 5, 2025. He alleged

that in July 2022, he lost water for three weeks because of a water-main break on

Marsdon Drive in Euclid, Ohio. He further alleged that the City made repairs at his

home on August 12, 2022. Jackson claimed in his complaint that the City was

negligent in “making the repairs” because it “filled the hole with concrete curb

debris,” which allegedly “caused the sewer line servicing his home to collapse.”

{¶ 4} Jackson further alleged that he did not discover this damage until

August 3, 2023, when he found sewer backup in the crawl space of his home.

Jackson stated in his complaint that his home is built over a crawl space that he can

access through a “hatch.” Jackson stores items in the crawl space, and his HVAC

system is in the crawl space as well. Jackson claims that he opened the hatch to access the crawl space after his girlfriend “noted flies and saw mice” in the garage

and that is when he discovered the sewer backup.

{¶ 5} According to Jackson’s complaint, he suffered property damage to

clothing and his HVAC system and he had to pay significant costs for cleanup.

Jackson demanded judgment against the City in the amount of $29.020.73, plus

attorney fees and costs.

{¶ 6} The City answered Jackson’s complaint and asserted several

defenses, including statute of limitations and political-subdivision immunity.

{¶ 7} The City filed a motion for judgment on the pleadings on August 8,

2025, claiming both that Jackson’s claims were barred by the statute of limitations

and that it was entitled to full immunity pursuant to R.C. Ch. 2744.

{¶ 8} The day before a response to the City’s motion was due, Jackson’s

counsel moved for an extension of time to respond to the City’s motion for judgment

on the pleadings. In it, Jackson’s counsel stated that he needed more time because

he was preparing for a criminal trial.

{¶ 9} Five days later, on August 26, 2025, the trial court granted the City’s

motion for judgment on the pleadings.

{¶ 10} Jackson subsequently moved the trial court to reconsider its decision.

The City opposed it, and the trial court denied it. Jackson timely appeals from the

trial court’s judgment granting the City’s motion for judgment on the pleadings. II. Law and Analysis

A. Standard of Review

{¶ 11} Within his first assignment of error, Jackson raises two issues. He

argues that the trial court erred when it granted the City’s motion for judgment on

the pleadings based on Jackson’s claims being barred by the statute of limitations.

He also argues that the trial court erred when it granted the City’s motion for

judgment on the pleadings based on political-subdivision immunity.

{¶ 12} Motions for judgment on the pleadings are governed by Civ.R. 12(C).

This rule provides that “[a]fter the pleadings are closed but within such time as not

to delay the trial, any party may move for judgment on the pleadings.” In ruling on

a Civ.R. 12(C) motion, the court is restricted to the allegations in the pleadings and

any writings attached as exhibits to the pleadings. Schmitt v. Educational Serv. Ctr.,

2012-Ohio-2210, ¶ 9 (8th Dist.). “‘Civ.R. 12(C) requires a determination that no

material factual issues exist and that the movant is entitled to judgment as a matter

of law.’” Rayess v. Educational Comm. for Foreign Med. Graduates,

2012-Ohio-5676, ¶ 18, quoting State ex rel. Midwest Pride IV, Inc. v. Pontious, 75

Ohio St.3d 565, 569-570 (1996). Judgment on the pleadings is appropriate where,

after considering the material allegations of the pleadings and all reasonable

inferences to be drawn therefrom in a light most favorable to the nonmoving party,

the court finds that the moving party is entitled to judgment as a matter of law. Id.

We review a trial court’s decision to grant a motion for judgment on the pleadings

de novo. Id. {¶ 13} Statute of limitations and immunity are affirmative defenses.

Covarrubias v. Lowe’s Home Improvement, 2021-Ohio-1658, ¶ 29 (8th Dist.); BCL

Ents., Inc. v. Ohio Dept. of Liquor Control, 77 Ohio St.3d 467, 471 (1997). Because

affirmative defenses typically rely on matters outside the complaint, they normally

cannot be raised in a motion to dismiss. Reasoner v. Columbus, 2003-Ohio-670,

¶ 12 (10th Dist.).1 If, however, the existence of an affirmative defense is obvious from

the face of the complaint, a court may grant a motion to dismiss on the basis of the

affirmative defense. Id.; see also Altier v. Valentic, 2004-Ohio-5641, ¶ 31 (11th

Dist.), quoting Loyer v. Turner, 129 Ohio App.3d 33, 35 (6th Dist. 1998) (requiring

the affirmative defense to be “‘obvious from the face of the complaint itself’”). Again,

the same reasoning applies to a motion for judgment on the pleadings except that

the court considers the pleadings and not just the complaint. Crenshaw at ¶ 12.

{¶ 14} However, a court must exercise caution because complaints do not

need to “‘anticipate and attempt to plead around defenses.’” Savoy v. Univ. of

Akron, 2012-Ohio-1962, ¶ 8 (10th Dist.), quoting United States v. N. Trust Co., 372

F.3d 886, 888 (7th Cir. 2004). Thus, unless the pleadings obviously or conclusively

establish the affirmative defense, a court may not grant judgment on the pleadings.

{¶ 15} We note that the trial court granted the City’s motion for judgment on

the pleadings without giving a reason. Regardless of whether the trial court gave a

1 The same reasoning applies to motions for judgment on the pleadings. See Crenshaw v.

Howard, 2022-Ohio-3914, ¶ 12 (8th Dist.) (“A motion for judgment on the pleadings is the same as a motion to dismiss filed after the pleadings have closed, and the same standard of review applies.”).

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Bluebook (online)
Jackson v. Cleveland, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jackson-v-cleveland-ohioctapp-2026.