Kappner v. Dolan

23 Ohio Law. Abs. 555, 8 Ohio Op. 275, 1937 Ohio Misc. LEXIS 1175
CourtCourt of Common Pleas of Ohio, Hamilton County
DecidedMarch 16, 1937
StatusPublished

This text of 23 Ohio Law. Abs. 555 (Kappner v. Dolan) is published on Counsel Stack Legal Research, covering Court of Common Pleas of Ohio, Hamilton County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kappner v. Dolan, 23 Ohio Law. Abs. 555, 8 Ohio Op. 275, 1937 Ohio Misc. LEXIS 1175 (Ohio Super. Ct. 1937).

Opinion

OPINION

By MORROW, J.

Plaintiff below filed suit in the Municipal Court of Cincinnati for damages sustained by his automobile in a collision. The defendant below, by cross bill of particulars, asked for damages sustained by his automobile in the collision. The case was tried without a jury and resulted in judgment for the defendant. In the judgment entry the court assessed the costs against both plaintiff and defendant. A notice of appeal on questions of law and fact was filed by plaintiff below and the court below by entry stated as follows (in part):

“The judgment of the court has already been carried out and the costs have been paid. The court upon consideration thereof finds that said notice of appeal upon questions of law and fact is not intended to operate as a stay of execution of the court’s judgment in the above entitled cause and will not so operate.

“It is therefore ordered by the court that no supersedeas bond or appeal bond be required of this plaintiff to perfect' his appeal to the Common Pleas Court, Hamilton County, Ohio.”

Transcript of the docket and journal entries was filed in this court, together with the original papers, and the document which was filed in this court and containing the same, is entitled “Appeal on Questions of Law and Facts.”

The plaintiff below also filed in this court a “Petition on Appeal”, and the defendant below has filed a motion to strike plaintiff’s “Petition on Appeal”-from the files, on the ground that no bond was filed and that the time for filing tfi? bond has elapsed.

We will refer to the parties herein as plaintiff and defendant, as their position in the caption is the same here as below.

Two primary questions are presented:

1. Under the new act providing for appellate review can appeal be perfected by notice of appeal without the filing of a bond, and is this true as to appeal on questions of law and facts, as well as appeal on questions of law?
2. Can appeal on questions of law and facts be taken from a judgment of the Municipal Court of Cincinnati?

I.

We will take up the last question first.

“More than 80 years ago, the Ohio General Assembly enacted the law of ‘Appeals’ and ‘Proceedings in Error’ * * *. Except a few changes, notably in 1913, * * * it has remained almost in its original form.
“In May, 1935, the Ohio Legislature repealed the earlier law and placed on the statute books a new law for appellate review, which becomes effective January 1, 1936. * * *”
“Under the new appellate procedure all review is regarded as a continuation of the case.” See Ohio Appellate Review and Forms. — -Dawson pages 1 and 3.
“The new act does not affect the jurisdiction of any court. It merely sets up a new method of procedure. The new method will supplant all error proceedings, from any court or administrative body to any court.” See Dawson, page 4.

Sec 12223-1, GC, reads-as follows:

“1. The word ‘appeal’ as used in this act shall be construed to mean all proceedings whereby one court reviews or retries a cause determined by another court, an administrative officer, tribunal or commission.
“2. The ‘appeal on questions of law’ shall be construed to mean a review of a cause upon questions of law including the weight and sufficiency of the evidence and shall include all the procedings heretofore and otherwise designated in the general code as proceedings in error.
“3. The -‘appeal on questions of law and fact’ shall be construed to mean a rehearing and retrial of a cause upon the law and the facts and shall include all the proceedings heretofore and otherwise designated as an appeal, and shall be the same as may be designated by the phrase ‘appeal on questions of fact’.”

[557]*557Comment:

“The term ‘appeal’ has heretofore been used in two senses: (1) to designate generally all appellate review, and (2) to designate the type of review in an Appellate Court. However, the first meaning will continue but the terms ‘appeal on questions of law’ and ‘appeal on questions of law and fact’ will be used to designate the type of review in an Appellate Court.” See Dawson, page 10.

Sec 12223-4, GC, reads as follows:

“The appeal shall be deemed perfected when written notice of appeal shall be filed with the lower court, tribunal, officer or commission. Where leave to appeal must be first obtained, notice of appeal shall also be filed in the appellate court. After being duly perfected, no appeal shall be dismissed without notice to the appellant, and no step required to be taken subsequent to the perfection of the appeal shall be deemed to be jurisdictional.”

Comment:

“This section is new. It is the key section of the act. Under the former system we regarded the appeal in a chancery case as a continuation of the case, but error procedings were new proceedings starting with a petition and receiving summons or waiver. The new system adopts the theory of the chancery appeal. The act does not require notice to be served upon the opposite party.
“Since the notice of appeal is the only jurisdictional step, there will be fewer dismissals by Appellate Courts on procedural grounds.” See Dawson, page 22.

Sec 12223-21 (2) GC provides as follows:

“(2) An appeal taken on questions of law and fact shall entitle the party to a hearing and determination of the facts de novo and shall be on the same or amended pleadings.”

Sec 1558-26 GC, which is part of the code of the Municipal Court of Cincinnati was amended at' the same time and to conform with the passage of the Appellate Procedure Act, and reads now as follows:

“Proceedings in error may be taken to the Common Pleas Court of Hamilton County, from a final order or judgment of the Municipal Court of Cincinnati in the same manner and under the same conditions as provided by law for proceedings in error from the Common Pleas Court to the Court of Appeals, of Hamilton County. In civil cases in which a judgment of more than three hundred dollars has been granted, or being prayed for has not been granted, proceedings in error from a final judgment or order of the Common Pleas Court of Hamilton County, upon * * * an appeal on questions of law from such final judgment or order of the Municipal' Court to the Common Pleas Court of Hamilton County, may be had as in other cases originating in said Common Pleas Court, to the Court of Appeals of Hamilton County. The review of all cases other than civil actions and proceedings shall be had in the manner provided for review of civil actions and proceedings in which a judgment for more than three hundred dollars has been granted. There shall be no appeal to the Court of Appeals of Hamilton County, from the Common Pleas Court of Hamilton County, in any action or proceeding brought on review from the Municipal Court of .Cincinnati, to the Common Pleas Court of Hamilton County.”

Dawson says as to this:

“The sections following were not in general language, and therefore required amendment to conform to §§12223-1 GC et seq.

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Cite This Page — Counsel Stack

Bluebook (online)
23 Ohio Law. Abs. 555, 8 Ohio Op. 275, 1937 Ohio Misc. LEXIS 1175, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kappner-v-dolan-ohctcomplhamilt-1937.