Lopez v. Thomas

2014 Ohio 2513
CourtOhio Court of Appeals
DecidedJune 11, 2014
Docket27115
StatusPublished
Cited by3 cases

This text of 2014 Ohio 2513 (Lopez v. Thomas) 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
Lopez v. Thomas, 2014 Ohio 2513 (Ohio Ct. App. 2014).

Opinion

[Cite as Lopez v. Thomas, 2014-Ohio-2513.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF SUMMIT )

LUTHER LOPEZ C.A. No. 27115

Appellant

v. APPEAL FROM JUDGMENT ENTERED IN THE JAZMINE THOMAS COURT OF COMMON PLEAS COUNTY OF SUMMIT, OHIO Appellee CASE No. CV 2012 09 5438

DECISION AND JOURNAL ENTRY

Dated: June 11, 2014

WHITMORE, Judge.

{¶1} Plaintiff-Appellant, Luther Lopez, appeals from the judgment of the Summit

County Court of Common Pleas. This Court affirms.

I

{¶2} In June 2012, Lopez and Defendant-Appellee, Jazmine Thomas, were both

employees of Labor Ready, a temporary employment agency. It was customary for Labor Ready

employees to ride together to their assigned work locations after reporting to Labor Ready in the

morning. On June 11, 2012, Lopez and Thomas were assigned to work at the McJak Candy

Company (“McJak Candy”) and rode there together.

{¶3} Two days after their shared ride, Thomas supplied Labor Ready with a written

statement about Lopez. Thomas wrote that, during their car ride together, Lopez divulged that he

was going to file a grievance against their supervisor at McJak Candy. The grievance would

accuse the supervisor of racial discrimination. According to Thomas, Lopez said that he was 2

filing the grievance as a preventative measure because he felt that the supervisor was planning on

telling Labor Ready not to assign him to work at McJak Candy anymore. According to Thomas,

Lopez also said that he had employed similar tactics with companies in the past to avoid

termination or to seek compensation and that he was very knowledgeable about civil law.

Thomas told her supervisor at McJak Candy what Lopez had said.

{¶4} The day after Thomas wrote her statement, Lopez drove to Labor Ready and

confronted Thomas in the parking lot. When their conversation ended, Thomas went inside and

told one of the Labor Ready staff members that Lopez had threatened her. Lopez was then asked

to leave the premises. Labor Ready asked Thomas to complete a written statement about the

incident, but Thomas did not immediately do so. Instead, she completed a statement on June 22,

2012, eight days after the conversation occurred. In her statement, Thomas wrote that she “was

threatened by” Lopez after he asked her whether she had “‘snitched’ on him.” Thomas further

wrote that Lopez “said that he was used to f***ing people up that ‘snitched’ on him because he

had been to jail” and that “[h]e told [her] that if he found out that [she] ‘snitched’ on him he

would f*** [her] up too.” Unbeknownst to Thomas, Lopez had recorded the conversation that

the two of them had in the parking lot.

{¶5} Subsequently, Lopez filed a defamation suit against Thomas for libel and slander

per se, alleging that he had been damaged as a result of her attributing statements to him that he

had never made. Thomas filed an answer as well as counterclaims for assault and civil liability

for criminal conduct under R.C. 2307.60. After the parties exchanged discovery, however,

Thomas dismissed her counterclaims. The matter proceeded to a bench trial.

{¶6} At the close of Lopez’ case-in-chief, Thomas moved for a directed verdict. The

court granted a directed verdict with regard to the verbal statements that Thomas had made. 3

Specifically, the court found that Lopez had failed to prove that Thomas’ oral statements (that

she was threatened by Lopez) were false. The court denied the motion for directed verdict with

regard to Thomas’ written statements, however, and the defense presented its case-in-chief. At

the close of the evidence, the court entered a judgment of dismissal in favor of Thomas.

{¶7} Lopez now appeals and raises five assignments of error for our review. For ease

of analysis, we consolidate all five assignments of error.

II

Assignment of Error Number One

THE COURT ERRED BY NOT APPLYING THE CORRECT STANDARD IN REGARD TO APPELENTS (sic) BURDEN AS TO PROOF OF NEGLIGENCE IN LIGHT OF THE FACT THAT APPELLEES (sic) CONDUCT WAS AN ASPECT OF NEGLIGENCE AS SHOWN BY THE EVIDENCE AND TESTIMONY PRESENTED.

Assignment of Error Number Two

THE COURT ERRED IN ASSUMING SOME SPECIFIC OR RELATED GROUNDS FOR RELIEF WAS PRESENTED BY APPELLEE’S COUNSEL YET NO SUBSTANTIAL OR SPECIFIC REASON FOR THE DIRECTED VERDICT WAS PRESENTED TO THE COURT.

Assignment of Error Number Three

THE COURT ERRED IN NOT EMPLOYING A RECKLESSNESS STANDARD IN FAILING TO CONSIDER THAT THE APPELLEE’S CONDUCT WAS IN ITSELF RECKLESS AND ESTABLISHED NEGLIGENCE. (Emphasis sic.)

Assignment of Error Number Four

THE COURT ERRED BY NOT WEIGHING SUFFICIENCY OF THE TESTIMONY AND AUDIO/VIDEO EVIDENCE IN A LIGHT MOST FAVORABLE TO APPELLANT.

Assignment of Error Number Five

THE COURT ERRED IN NOT APPLYING A CLEAR AND CONVINCING EVIDENCE STANDARD WHEN IT DETERMINED WHETHER THE APPELLEES (sic) DIRECTED VERDICT ESTABLISHED ANY PROXIMATE 4

CAUSE TO OUTWEIGH THE MANIFEST WEIGHT OF THE EVIDENCE OR TESTIMONY.

{¶8} In his assignments of error, Lopez argues that the trial court applied the incorrect

legal standard when analyzing various concepts and that its ultimate decision to enter judgment

in favor of Thomas was in error. We disagree.

{¶9} Initially, we note that Lopez represented himself in the court below and also

appears pro se on appeal. With respect to pro se litigants, this Court has observed that

pro se litigants should be granted reasonable leeway such that their motions and pleadings should be liberally construed so as to decide the issues on the merits, as opposed to technicalities. However, a pro se litigant is presumed to have knowledge of the law and correct legal procedures so that he remains subject to the same rules and procedures to which represented litigants are bound. He is not given greater rights than represented parties, and must bear the consequences of his mistakes. This Court, therefore, must hold [pro se appellants] to the same standard as any represented party.

(Internal citations omitted.) Sherlock v. Myers, 9th Dist. Summit No. 22071, 2004-Ohio-5178, ¶

3; Countrywide Home Loans Servicing, L.P. v. Murphy-Kesling, 9th Dist. Summit No. 25297,

2010-Ohio-6000, ¶ 4. “[W]hile this Court has made every effort to determine and address the

merits of [Lopez’] contentions, he is subject to the same rules and procedures as if he were

represented by an attorney.” State v. Charlton, 9th Dist. Lorain No. 12CA010206, 2014-Ohio-

1330, ¶ 6.

{¶10} “Defamation is a false publication that injures a person’s reputation.” Gosden v.

Louis, 116 Ohio App.3d 195, 206 (9th Dist.1996). “Written defamation is known as libel;

spoken defamation is known as slander.” Id. at 206. “To prevail in a defamation case, a plaintiff

who is a private person must prove five elements: ‘(1) a false and defamatory statement, (2)

about plaintiff, (3) published without privilege to a third party, (4) with fault of at least

negligence on the part of the defendant, and (5) that was either defamatory per se or caused 5

special harm to the plaintiff.’” Northeast Ohio Elite Gymnastics Training Ctr., Inc. v. Osborne,

183 Ohio App.3d 104, 2009-Ohio-2612, ¶ 7 (9th Dist.), quoting Gosden at 206. Damages are

presumed if the matter is defamatory per se, but a defamation plaintiff still must prove the

remaining elements of his or her defamation case. See Gosden at 209.

{¶11} “Insofar as the truth or falsity of the defamatory statement is concerned, the

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2014 Ohio 2513, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lopez-v-thomas-ohioctapp-2014.