Margiman v. Dowdell

2025 Ohio 377
CourtOhio Court of Appeals
DecidedFebruary 6, 2025
Docket114202
StatusPublished
Cited by1 cases

This text of 2025 Ohio 377 (Margiman v. Dowdell) 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
Margiman v. Dowdell, 2025 Ohio 377 (Ohio Ct. App. 2025).

Opinion

[Cite as Margiman v. Dowdell, 2025-Ohio-377.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

AUREL MARGIMAN, ET AL., :

Plaintiffs-Appellees, : No. 114202 v. :

TINA DOWDELL, :

Defendant-Appellant. :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED RELEASED AND JOURNALIZED: February 6, 2025

Civil Appeal from the Cuyahoga County Court of Common Pleas Case No. CV-02-472676

Appearances:

Tina Dowdell, pro se.

DEENA R. CALABRESE, J.:

Defendant-appellant, Tina Dowdell (“Dowdell”), appeals the trial

court’s denial of her motion to vacate a default judgment. We find the trial court did

not abuse its discretion in denying Dowdell’s motion, and therefore affirm the trial

court’s denial of Dowdell’s motion to vacate default judgment. I. Facts and Procedural History

The record reflects that on June 7, 2002, plaintiffs-appellees State

Farm Automobile Insurance Co., Aurel Margiman, and Lucinda Ward (collectively

“State Farm parties”) filed a complaint to recover a debt against Dowdell. The clerk

of the Cuyahoga County Common Pleas Court sent service of the complaint to

Dowdell by certified mail to 11826 McGowan, Cleveland, Ohio (the “McGowan

address”). The service was returned to the clerk marked unclaimed on July 12,

2002. On July 24, 2002, the clerk sent service of the complaint to Dowdell by

ordinary mail. The ordinary mail service was not sent back, and Dowdell did not file

an answer. The trial court granted State Farm’s motion for default judgment on

September 30, 2002, and judgment was entered in favor of the State Farm parties

and against Dowdell in the amount of $5,138.59, with interest as allowed by law,

plus costs.

Almost 22 years later, Dowdell discovered the judgment against her

while attempting to obtain a driver’s license at the Ohio Bureau of Motor Vehicles.

On May 22, 2024, Dowdell filed a motion to vacate the default judgment. Attached

to Dowdell’s motion was an unsigned but notarized affidavit stating that she had not

lived at the McGowan address for a year prior to service of the complaint. On

June 27, 2024, the trial court denied Dowdell’s motion to vacate, stating:

Deft’s pro se motion to vacate void judgment filed 05/22/2024, is denied. (1) Deft filed an unsigned affidavit with a notary attestation. (2) Deft must challenge judgment in compliance with Civ.R. 60(B)[.] (3) Deft must serve the opposing party with the motion. Clerk of Courts to serve a copy of this order to: tinadowdell.3652@gmail.com so ordered. Notice issued.

The present appeal stems from this order.

II. Law and Analysis

Appellant raises the following assignment of error for our review:

The trial court erred by denying appellant’s motion to vacate void judgment when service of the complaint was never perfected upon appellant thus depriving the trial court of jurisdiction.

Dowdell also argues that the trial court erred when it directed her to challenge the

judgment in compliance with Civ.R. 60(B) and to serve the parties.

‘“[T]o enter a valid judgment, a court must have personal jurisdiction

over the defendant.’” Midland Funding, L.L.C. v. Cherrier, 2020-Ohio-3280, ¶ 9

(8th Dist.), quoting Mayfran Internatl., Inc. v. Eco-Modity, L.L.C., 2019-Ohio-

4350, ¶ 9 (8th Dist.), citing Maryhew v. Yova, 11 Ohio St.3d 154, 156 (1984). A

judgment rendered without personal jurisdiction is void. GGNSC Lima, L.L.C. v.

LMOP, L.L.C., 2018-Ohio-1298, ¶ 14 (8th Dist.), citing Patton v. Diemer, 35 Ohio

St.3d 68 (1988), paragraph three of the syllabus.

A court acquires personal jurisdiction over a defendant when (1) the

defendant is properly served with the complaint and summons, (2) the defendant

makes a voluntary appearance in the case, or (3) “limited acts by the party or his

counsel that involuntarily submit him to the court’s jurisdiction.” GGNSC Lima at

¶ 14; Austin v. Payne, 107 Ohio App.3d 818, 821 (9th Dist. 1995), citing Maryhew at

156. Service of process is governed by Civ.R. 4.1 through 4.6. Civ.R.

4.1(A)(1)(a) authorizes service within this State to be sent by the clerk’s office via

certified mail by the United States Postal Service. If the certified mail is returned

with an endorsement stating that the envelope was unclaimed, then the attorney can

request that service be sent by ordinary mail. “Service shall be deemed complete

when the fact of mailing is entered of record, provided that the ordinary mail

envelope is not returned by the postal authorities with an endorsement showing

failure of delivery.” Civ.R. 4.6(D).

The plaintiff bears the burden of obtaining proper service on a

defendant. Cincinnati Ins. Co. v. Emge, 124 Ohio App.3d 61, 63 (1st Dist. 1997).

Where the plaintiff follows the civil rules governing service of process, courts

presume that service is proper unless the defendant rebuts this presumption with

sufficient evidence of nonservice. Hook v. Collins, 2017-Ohio-976, ¶ 14 (8th Dist.),

citing Carter-Jones Lumber Co. v. Meyers, 2006-Ohio-5380, ¶ 11 (2d Dist.).

“‘“Where the defendant files a motion to vacate judgment, and swears under oath

that he or she did not reside at the address to which process was sent, the

presumption is rebutted, and it is incumbent upon the plaintiff to produce evidence

demonstrating that defendant resided at the address in question.”’” Midland

Funding, 2020-Ohio-3280, at ¶ 9 (8th Dist.), quoting Hook at ¶ 15, quoting Watts

v. Brown, 1983 Ohio App. LEXIS 15311, *14-15 (8th Dist. Aug. 4, 1983).

The “presumption of proper service may be rebutted by evidence that

the defendant did not reside, nor received mail, at the address to which such ordinary mail service was addressed.” Hook at ¶ 15, citing McWilliams v.

Schumacher, 2013-Ohio-29, ¶ 49 (8th Dist.), citing Cent. Ohio Sheet Metal, Inc. v.

Walker, 2004-Ohio-2816, ¶ 10 (10th Dist.). “[T]o rebut the presumption of proper

service, the [defendant] must produce evidentiary-quality information

demonstrating that he or she did not receive service.” McWilliams at ¶ 51;

Hathaway Brown School v. Cummings, 2023-Ohio-374, ¶ 12 (8th Dist.). An

unsigned affidavit has no evidentiary value. Morrison v. Kemper Ins. Co., 2003-

Ohio-5655, ¶ 6 (8th Dist.); State ex rel. Dawson v. Bloom-Carroll Local School Dist.,

131 Ohio St.3d 10 (2011).

The trial court’s judgment regarding the validity of service is reviewed

for an abuse of discretion. Midland Funding at ¶ 13, citing GGNSC Lima, 2018-

Ohio-1298, at ¶ 15 (8th Dist.). A court abuses its discretion when it ‘“applies the

wrong legal standard, misapplies the correct legal standard, or relies on clearly

erroneous findings of fact.’” Id., quoting Thomas v. Cleveland, 2008-Ohio-1720,

¶ 15 (8th Dist.), citing Berger v. Mayfield Hts., 265 F.3d 399, 402 (6th Cir. 2001).

In this case, the clerk sent service of the complaint to Dowdell by

certified mail with the United States Postal Service. The certified mail service was

returned marked “unclaimed.” The clerk then sent the service by ordinary mail on

July 24, 2002, and, per Civ.R. 4.6, service on Dowdell was perfected on that date.

When she did not file an answer, the court granted State Farm’s motion for default

judgment. Dowdell filed a motion to vacate default judgment on May 22, 2024,

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Bluebook (online)
2025 Ohio 377, Counsel Stack Legal Research, https://law.counselstack.com/opinion/margiman-v-dowdell-ohioctapp-2025.