Liles v. Sporing

2025 Ohio 626
Ohio Court of Appeals·Decided February 26, 2025·No. C-240439·Published

Opinion

IN THE COURT OF APPEALS

FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

JEFFREY LILES, : APPEAL NO. C-240439 TRIAL NO. A-2202758

Plaintiff-Appellant, :

vs. :

OPINION

RICHARD SPORING, :

Defendant-Appellee. :

Civil Appeal From: Hamilton County Court of Common Pleas Judgment Appealed From Is: Reversed and Cause Remanded Date of Judgment Entry on Appeal: February 26, 2025

Jones Kahan Law, LLC, Joel A. Buckley, David M. Jones and Michael S. Kahan, for Plaintiff-Appellant,

Curry Roby, LLC, and Lisa C. Haase, for Defendant-Appellee.

BOCK, Judge.

{¶1} Plaintiff-appellant Jeffrey Liles sued defendant-appellee Richard Sporing in July 2020. Liles, however, failed to perfect service on Sporing. Nearly two years later, after the statute of limitations time limit had expired, Liles voluntarily dismissed his complaint. Within one year of that dismissal, Liles refiled his lawsuit.

{¶2} Ohio’s savings statute, R.C. 2305.19, permits a plaintiff who complies with its requirements to refile a complaint after the statute of limitations has expired. Relevant here, the savings statute applies if the first action failed “otherwise than upon the merits.” R.C. 2305.19(A). And a plaintiff’s first voluntary dismissal under Civ.R. 41(A)(1)(a) is a failure otherwise than upon the merits for the purpose of applying the savings statute. See Frysinger v. Leech, 32 Ohio St.3d 38, 43 (1987).

{¶3} In this appeal, we examine whether Liles’s Civ.R. 41(A)(1)(a) voluntary dismissal was a failure “otherwise than upon the merits.” See R.C. 2305.19(A). In so doing, we analyze whether Moore v. Mt. Carmel Health Sys., 2020-Ohio-4113, adds any requirements to the savings statute where, as here, a plaintiff fails to obtain service, then voluntarily dismisses the complaint after Civ.R. 3(A)’s commencement period has expired and after the statute of limitations time has run.

{¶4} We hold that Moore does not add unwritten requirements to the plain, unambiguous language of the savings statute. Following Moore, the Supreme Court of Ohio emphasized that the starting place in analyzing savings-statute cases is the plain language of the statute itself. See McCullough v. Bennett, 2024-Ohio-2783, ¶ 10. Under its plain language, the savings statute applies if the first action failed “otherwise than upon the merits.” And Civ.R. 41(A)(1) unambiguously states that a plaintiff’s first voluntary dismissal is “without prejudice.” Accordingly, the savings statute applied to save Liles’s action. We reverse the trial court’s judgment.

I. Factual and Procedural History

{¶5} In July 2020, Liles sued Sporing to recover for injuries he sustained in a July 2019 bicycle-vehicle collision with Sporing (“2020 action”). Liles requested certified mail service on Sporing, which the clerk issued in July 2020. That service was returned unclaimed. Liles took no further action to perfect service on Sporing. Sporing, however, appeared in the 2020 action, which proceeded through discovery. In February 2022, Sporing moved to dismiss the lawsuit, asserting that Liles had failed to perfect service. Nine days later, with Sporing’s motion still pending, Liles voluntarily dismissed the 2020 action under Civ.R. 41(A)(1)(a).

{¶6} In August 2022, Liles refiled his complaint (“2022 action”). Sporing moved for summary judgment, arguing that the 2022 action was barred by the statute of limitations. Sporing asserted that because Liles had failed to perfect service on him in the 2020 action within Civ.R. 3(A)’s one-year commencement period and within the statutory time limit, Ohio’s saving statute did not apply to save Liles’s action. Liles opposed the motion, arguing that he met the savings statute’s requirements because he had voluntarily dismissed his 2020 complaint without prejudice.

{¶7} The trial court granted Sporing’s summary-judgment motion, holding that the Supreme Court of Ohio’s decision in Moore required judgment in Sporing’s favor.

II. Analysis

{¶8} In one assignment of error, Liles asserts that the trial court erroneously dismissed his 2022 action because the savings statute applied to save his lawsuit.

A. Standard of review

{¶9} We review a trial court’s summary-judgment ruling de novo.

Environmental Solutions & Innovations, Inc. v. Edge Eng. & Science, LLC, 2023-

Ohio-2605, ¶ 6 (1st Dist.). Summary judgment must be granted where (1) there are no genuine issues of material fact, (2) the movant is entitled to judgment as a matter of law, and (3) when viewing the evidence most strongly in the nonmovant’s favor, reasonable minds can only come to a conclusion that is adverse to the nonmovant. Civ.R. 56(C); see M.H. v. City of Cuyahoga Falls, 2012-Ohio-5336, ¶ 12.

{¶10} A court interpreting a statute must give effect to the legislature’s intent.

Ayers v. City of Cleveland, 2020-Ohio-1047, ¶ 17. Our starting point is the language of the statute itself. Id. “If the statute’s language is plain and unambiguous, we apply it as written.” State v. Bollar, 2022-Ohio-4370, ¶ 10.

B. Statute of limitations and Ohio’s savings statute

{¶11} “[A]n action for bodily injury . . . shall be brought within two years after the cause of action accrues.” R.C. 2305.10(A). A claim is time-barred unless it is commenced within the applicable statute-of-limitations period. Moore, 2020-Ohio- 4113, at ¶ 1. Under Civ.R. 3(A), a plaintiff commences an action by filing a complaint and perfecting service within a year of the filing. Accordingly, “to comply with the statute of limitations, an action must be ‘commenced’ within the limitations period. Under Civ.R. 3(A), this occurs when the action is filed within the limitations period and service is obtained within one year of that filing.” Moore at ¶ 16.

{¶12} Ohio’s savings statute creates “‘an exception to the general bar of the statute of limitations’” and permits a plaintiff to refile a lawsuit after the statute of limitations has elapsed if the plaintiff meets R.C. 2305.19(A)’s terms. McCullough, 2024-Ohio-2783, at ¶ 11, quoting Wilson v. Durrani, 2020-Ohio-6827, ¶ 11. Ohio’s savings statute provides:

In any action that is commenced or attempted to be commenced, if in due time a judgment for the plaintiff is reversed or if the plaintiff fails

otherwise than upon the merits, the plaintiff . . . may commence a new action within one year after the date of the reversal of the judgment or the plaintiff’s failure otherwise than upon the merits or within the period of the original applicable statute of limitations, whichever occurs later.

R.C. 2305.19(A).

{¶13} The plain language of the savings statute contains three requirements for the statute to apply to save a lawsuit: (1) the plaintiff must have commenced or attempted to commence the first action, (2) the first action must have been reversed or have failed otherwise than upon the merits, and (3) the plaintiff must have commenced the second action within one year after the failure of the first action, or within the original statutory-limitation period, “whichever occurs later.” Id.; McCullough at ¶ 2.

{¶14} Liles alleged that he was injured on July 24, 2019. Therefore, the statute of limitations was set to expire on July 24, 2021. But the COVID-19 pandemic tolled time limitations, causing the statutory-limitations period to expire on December 14, 2021. Liles filed his second action in August 2022, outside of the statute of limitations. Thus, the 2022 action was untimely unless the savings statute applied.

{¶15} There is no dispute that Liles met the first and third requirements under the savings statute. The sole issue is whether Liles’s 2020 action failed “otherwise than upon the merits.”

1. A first voluntary dismissal fails otherwise than upon the merits

{¶16} In March 2022, Liles voluntarily dismissed the 2020 action under Civ.R. 41(A)(1)(a). When he dismissed the action, he had not perfected service on Sporing, despite it being more than one year after Liles filed the first suit—beyond

Civ.R. 3(A)’s one-year commencement time,1 and after the statutory-limitation period had expired.

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