Katakis v. Hahn

2024 Ohio 1210, 241 N.E.3d 305
CourtOhio Court of Appeals
DecidedMarch 29, 2024
Docket2023WD0035
StatusPublished
Cited by1 cases

This text of 2024 Ohio 1210 (Katakis v. Hahn) 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
Katakis v. Hahn, 2024 Ohio 1210, 241 N.E.3d 305 (Ohio Ct. App. 2024).

Opinion

[Cite as Katakis v. Hahn, 2024-Ohio-1210.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: SIXTH JUDICIAL DISTRICT COUNTY OF WOOD )

GEORGE KATAKIS, et al. C.A. No. 2023WD0035

Appellees

v. APPEAL FROM JUDGMENT ENTERED IN THE BROOKE HAHN, et al. COURT OF COMMON PLEAS COUNTY OF WOOD, OHIO Appellant CASE No. 2022CV0424

DECISION AND JOURNAL ENTRY

Dated: March 29, 2024

HENSAL, Judge.

{¶1} Brooke Hahn appeals an order of the Wood County Court of Common Pleas that

denied her motion for judgment on the pleadings. For the following reasons, this Court affirms.

I.

{¶2} George and Betty Katakis own a parcel of land in Troy Township that was

originally zoned for agricultural use. In 2018, they asked the Township to rezone a corner of the

parcel for commercial use. The Township granted their request. In 2019, the Katakises sought to

develop the rest of the parcel as a subdivision of single-family homes. They, therefore, filed

another application for rezoning, which the Township granted, changing the land to residential

use. According to the Katakises, the second application only applied to the part of the parcel that

was still zoned agricultural. Ms. Hahn, the Township’s zoning inspector, however, has taken the

position that the second zoning resolution changed the entire parcel to residence use, including the

corner that had been rezoned as commercial. 2

{¶3} The Katakises filed a complaint, which they later amended, against Ms. Hahn, the

Township, and the county recorder, seeking a declaration that the corner of their property is zoned

commercial and an injunction that would prohibit the Township from taking any other position.

They also sued Ms. Hahn for intentional interference with a business relationship. After Ms. Hahn

and the Township filed an answer, the Katakises moved for partial judgment on the pleadings on

their declaratory judgment claim. Ms. Hahn and the Township also moved for partial judgment

on the pleadings, arguing that the declaratory judgment and injunction causes of action are barred

and without merit, and that Ms. Hahn is immune from liability under Revised Code Section

2744.03(A)(6).

{¶4} The trial court denied both motions. It determined that both sides had reasonable

interpretations of the Township’s zoning resolutions and that the ambiguity of the resolutions could

not be determined from the pleadings. Regarding the tortious interference claim against Ms. Hahn,

it determined it could not say from the pleadings that the Katakises can prove no set of facts that

would entitle them to relief. Ms. Hahn has appealed, assigning as error that the trial court

incorrectly denied her immunity under Section 2744.03(A)(6).

II.

ASSIGNMENT OF ERROR

THE LOWER COURT ERRONEOUSLY DENIED DEFENDANT/APPELLANT BROOKE HAHN THE BENEFIT OF IMMUNITY UNDER R.C. 2744.03(A)(6).

{¶5} Ms. Hahn argues that the trial court incorrectly denied her judgment on the

pleadings on the Katakises’ intentional interference claim. She argues that, as an employee of a

political subdivision, she is entitled to immunity under Section 2744.03(A)(6). 3

{¶6} A motion for judgment on the pleadings is governed by Civil Rule 12(C). That 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, a court may

consider both the complaint and the answer, as well as any material attached as exhibits to those

pleadings.” Valentine v. Hood, 6th Dist. Lucas No. L-23-1046, 2023-Ohio-2250, ¶ 12. “Dismissal

is appropriate under Civ.R. 12(C) when (1) the court construes as true, and in favor of the

nonmoving party, the material allegations in the complaint and all reasonable inferences to be

drawn from those allegations and (2) it appears beyond doubt that the plaintiff can prove no set of

facts that would entitle him or her to relief.” Reister v. Gardner, 164 Ohio St.3d 546, 2020-Ohio-

5484, ¶ 17. Review of the trial court’s judgment is de novo. Id.

{¶7} Section 2744.03(A) provides a list of “defenses or immunities” that “may be

asserted to establish nonliability” “[i]n a civil action brought against * * * an employee of a

political subdivision[.]” Section 2744.03(A)(6) provides that, in addition to other immunities or

defense, an “employee is immune from liability unless one” of three conditions applies. The first

is if “[t]he employee’s acts or omission were manifestly outside the scope of the employee’s

employment or official responsibilities[.]” R.C. 2744.03(A)(6)(a). The second is if “[t]he

employee’s acts or omissions were with malicious purpose, in bad faith, or in a wanton or reckless

manner[.]” R.C. 2744.03(A)(6)(b). The third is if “[c]ivil liability is expressly imposed upon the

employee by a section of the Revised Code.” R.C. 2744.03(A)(6)(c). The Katakises alleged in

their amended complaint that Ms. Hahn did not have immunity under both Section

2744.03(A)(6)(a) and (b). In her motion, Ms. Hahn argued that none of the exceptions applied.

{¶8} Ms. Hahn argues that all the allegations against her relate to her position as the

Township’s zoning inspector, which includes a duty to enforce the Township’s zoning resolution. 4

It, therefore, can be inferred that she was acting in the course and scope of her position and that

Section 2744.03(A)(6)(a) does not apply. There also is no section of the Revised Code that

imposes liability on her, so Section 2744.03(A)(6)(c) does not apply.

{¶9} Regarding Section 2744.03(A)(6)(b), Ms. Hahn argues that the Katakises must do

more than merely allege that she acted with a malicious purpose, in bad faith, or in a wanton and

reckless manner. In Maternal Grandmother v. Hamilton County Department of Job and Family

Services, 167 Ohio St.3d 390, 2021-Ohio-4096, the Ohio Supreme Court held that notice pleading

is sufficient “when a complaint invokes the exception to a government employee’s immunity under

R.C. 2744.03(A)(6)(b)[.]” Id. at ¶ 11. It specifically rejected the idea that a plaintiff might be

“held to a heightened pleading standard or expected to plead the factual circumstances surrounding

an allegation of wanton or reckless behavior with particularity.” Id.; Gaither v. Kelleys Island

Local School Dist. Bd. of Edn., 6th Dist. Erie No. E-22-013, 2023-Ohio-1299, ¶ 33.

{¶10} The Katakises’ amended complaint alleges that Ms. Hahn engaged in deliberate

misconduct because she has claimed that the part of their property that was rezoned commercial

was included in the rezoning of the parcel to residential, contrary to the plain language of the

second zoning resolution. It also alleges that, despite being advised of her error, Ms. Hahn refuses

to remedy her misconduct or retract false statements she has made. When considering these

allegations in the context of a motion for judgment on the pleadings, we conclude that the

Katakises have sufficiently pleaded an exception to immunity. See Gaither at ¶ 35. We also

cannot say that there is no set of facts that would entitle the Katakises to relief on their claim. Id.

at ¶ 28, 35 (noting that “[b]ad faith” includes “conscious wrongdoing”), quoting Horen v. Bd. of

Edn. of Toledo Pub. Schools, 6th Dist. Lucas No. L-09-1143, 2010-Ohio-3631, ¶ 48. 5

{¶11} Ms. Hahn argues that her conduct cannot be deemed malicious, wanton, reckless,

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2024 Ohio 1210, 241 N.E.3d 305, Counsel Stack Legal Research, https://law.counselstack.com/opinion/katakis-v-hahn-ohioctapp-2024.