Loftus v. Three Palms Crocker Park, L.L.C.

2023 Ohio 926
CourtOhio Court of Appeals
DecidedMarch 23, 2023
Docket111635
StatusPublished
Cited by1 cases

This text of 2023 Ohio 926 (Loftus v. Three Palms Crocker Park, L.L.C.) 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
Loftus v. Three Palms Crocker Park, L.L.C., 2023 Ohio 926 (Ohio Ct. App. 2023).

Opinion

[Cite as Loftus v. Three Palms Crocker Park, L.L.C., 2023-Ohio-926.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

GERARD LOFTUS, ET AL., :

Plaintiffs-Appellants, : No. 111635 v. :

THREE PALMS CROCKER PARK, LLC, : ET AL., : Defendants-Appellees.

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED AND REMANDED RELEASED AND JOURNALIZED: March 23, 2023

Civil Appeal from the Cuyahoga County Court of Common Pleas Case No. CV-20-932382

Appearances:

Flowers & Grube, Paul W. Flowers, Louis E. Grube, and Melissa A. Ghrist; Charles V. Longo Co., L.P.A. and Charles V. Longo, for appellant.

Bailey Cavalieri LLC, Elan Kandel, Sabrina Haurin, and Elizabeth E. Cary, for appellee State Automobile Mutual Insurance Company.

Glowacki, Imbrigiotta & Doucette, L.P.A., and Stephen B. Doucette; Schneider, Smeltz, Spieth, Bell LLP and Thomas J. Connick, for appellee Three Palms Crocker Park, LLC. MICHELLE J. SHEEHAN, P.J.:

This case involves whether an employer and its insurer are liable for

a motor vehicle accident caused by an employee. The issue is whether the employee

was in the course and scope of employment and/or acting in furtherance of the

employer’s business at the time of the accident. Based upon the undisputed material

facts in this case, we affirm the trial court’s order granting summary judgment

because the employee involved in the motor vehicle accident was neither acting

within the scope of his employment nor acting in furtherance of the employer’s

business.1

I. Procedural History and Factual Overview

On March 1, 2019, plaintiff-appellant Gerard Loftus was severely

injured as a passenger in a single-car accident in which defendant-appellant Robert

Sotka was the driver. The accident occurred in Ottawa County, Ohio as Sotka was

driving to Westlake, Ohio.

Sotka was the manager at the Three Palms pizzeria restaurant at

Crocker Park in Westlake, Ohio. Sotka was a social acquaintance and friend of

Loftus, and Loftus was a frequent patron of the restaurant. In fact, both men had an

1 This case is a companion case to Loftus v. Three Palms Crocker Park, LLC, 8th Dist. Cuyahoga No. 111639, in which Sotka appeals the same judgment entry granting summary judgment. apartment near the restaurant in Crocker Park and socialized together multiple

times a week.

Sotka had discussions with Loftus about potentially purchasing a

restaurant with him. One restaurant that was briefly discussed was the Canoe Club

in Catawba Island Township, near one of Loftus’s homes. Another restaurant was

Flip Side Restaurant in Rocky River, Ohio. A letter of intent had been drafted and

was scheduled to be signed by Loftus and Sotka on March 4, 2019, regarding the

purchase of Flip Side.

On Friday, March 1, 2019, Sotka left the restaurant at 5:15 p.m. and

traveled over 60 miles to the Canoe Club to meet Loftus and a group of Loftus’s

friends. While Loftus testified that he was not interested in investing in the Canoe

Club because of the seasonal nature of the business, Sotka wanted to introduce

Loftus to the owner of the Canoe Club that night. When he arrived at the Canoe Club

at 6:20 p.m., Sotka had a tour of the Canoe Club from the owner and joined Loftus

and his friends for a drink. After socializing with everyone at the Canoe Club, Sotka

went to another bar in the area with Loftus and his friends, and later went to back

to one of the friends’ homes.

At around 10:00 p.m., Sotka decided to leave the group and return to

Westlake, Ohio. He stated that he intended to return to the restaurant before

11:00 p.m. to supervise closing. Although the restaurant closed at 10:00 p.m., Sotka

testified that on occasion he kept the restaurant open for customers after the posted

closing time. Loftus, who was scheduled to spend the night at his friend’s house that night, changed his mind and agreed to ride with Sotka back to Westlake, Ohio.

While Sotka made statements after the accident that he was taking Loftus home that

night, he later supplied an affidavit that he was taking Loftus to the restaurant. He

also testified in deposition that he would have either dropped Loftus off at home or

taken him to the restaurant, depending on what Loftus wanted. That decision was

never made because of the accident, and Loftus had no memory of the events of the

evening.

At around 10:15 p.m., Sotka was driving on State Route 52 in Ottawa

county, exceeding a speed of 120 m.p.h. The car left the road and hit a guardrail,

causing extensive damage. Sotka’s passenger, Loftus, suffered extensive and

permanent injuries. As a result of his driving, Sotka was later convicted in the

Ottawa County Court of Common Pleas of the crimes of Operating a Vehicle under

Impairment while having a blood alcohol content above the legal limit, a

misdemeanor of the first degree, and Vehicular Assault, a felony of the fourth

degree.

On May 6, 2020, Loftus filed a complaint against Sotka and Three

Palms. He alleged that Sotka was liable for his injuries and that Three Palms, as

Sotka’s employer, was vicariously liable because at the time of the accident, Sotka

was acting within the course and scope of his employment or acting as an agent of

Three Palms. State Auto Mutual Insurance Company (“State Auto”), who had issued

Three Palms a business insurance policy, intervened in the lawsuit and sought a

declaratory judgment action that it need not provide a defense or coverage because the accident that resulted in Loftus’s injuries was not covered by the insurance

policy.

State Auto and Three Palms filed motions for summary judgment.

Three Palms argued that it was not vicariously liable because Sotka was not

conducting or furthering its business when he crashed his car injuring Loftus.

Similarly, State Auto argued that Three Palms’ policy excluded the incident because

Sotka was not using his car in Three Palms’ business.

Sotka filed a summary judgment motion alleging that Three Palms

was liable for the accident as well as asserting the accident was covered by the State

Auto insurance policy. Loftus filed a motion for summary judgment arguing the

same and seeking a determination of liability against Sotka.

The trial court granted summary judgment to both Three Palms and

State Auto, granted Loftus summary judgment in part, and denied Sotka’s motion

for summary judgment.2 In granting Three Palms’ and State Auto’s motions for

summary judgment, the trial court found that there were “no genuine issues of

material fact that Defendant Sotka was not within the course and scope of his

employment with defendant Three Palms Crocker Park, LLC at the time of the

subject accident [and] there is no coverage for the subject accident under State

Auto’s insurance policy.”

2 Loftus’s claims against Sotka remain pending in the trial court. II. Law and Argument

A. Assignment of Error

Loftus appeals, asserting the following assignment of error:

The trial court erred in granting summary judgment to plaintiff- appellee State Automobile Mutual Insurance Company on its intervening complaint for declaratory relief, erred in denying Mr. Sotka’s cross-motion for summary judgment, and erred in declaring that there is no insurance coverage for the subject accident under the business owners’ insurance policy issued to defendant-appellee Three Palms Crocker Park, LLC. (May 19, 2022 Order.

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Bluebook (online)
2023 Ohio 926, Counsel Stack Legal Research, https://law.counselstack.com/opinion/loftus-v-three-palms-crocker-park-llc-ohioctapp-2023.