McCreary v. Taylor Cadillac, Inc.

2025 Ohio 2562
CourtOhio Court of Appeals
DecidedJuly 21, 2025
Docket1-24-67
StatusPublished

This text of 2025 Ohio 2562 (McCreary v. Taylor Cadillac, Inc.) 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
McCreary v. Taylor Cadillac, Inc., 2025 Ohio 2562 (Ohio Ct. App. 2025).

Opinion

[Cite as McCreary v. Taylor Cadillac, Inc., 2025-Ohio-2562.]

IN THE COURT OF APPEALS OF OHIO THIRD APPELLATE DISTRICT ALLEN COUNTY

TIAH MCCREARY, CASE NO. 1-24-67

PLAINTIFF-APPELLANT,

v.

TAYLOR CADILLAC, INC., ET AL., OPINION AND JUDGMENT ENTRY DEFENDANTS-APPELLEES.

Appeal from Allen County Common Pleas Court Trial Court No. CV2024 0191

Judgment Reversed in Part, Affirmed in Part and Cause Remanded

Date of Decision: July 21, 2025

APPEARANCES:

Randy L. Reeves for Appellant

Peter A. Demczuk for Appellees Case No. 1-24-67

WILLAMOWSKI, J.

{¶1} Plaintiff-appellant Tiah McCreary (“McCreary”) appeals the judgment

of the Allen County Court of Common Pleas, arguing that the trial court erred in

granting the motion to compel arbitration filed by Defendant-Appellee Taylor

Cadillac, Inc. (“Taylor Cadillac”), D.B.A. Taylor Kia of Lima (“Taylor Kia”). For

the reasons set forth below, the judgment of the trial court is affirmed in part and

reversed in part.

Facts and Procedural History

{¶2} In 2012, Taylor Cadillac opened a dealership in Lima, Ohio and

conducted a portion of their operations under the trade name “Taylor Kia of Lima.”

On February 29, 2024, McCreary went to Taylor Kia in search of a vehicle and

selected a car. Justin Nance (“Nance”), the finance and insurance manager at the

dealership, then presented McCreary with a series of documents that he reviewed

with her. McCreary signed a Retail Buyers Order (“RBO”) in addition to several

other documents. Nance then placed a copy of her electronic signature onto an

arbitration agreement.

{¶3} To assist with the process of obtaining financing, Nance helped

McCreary submit her information to Global Lending Services, LLC (“GLS”). Once

GLS had provided preliminary approval for a loan in the required amount,

McCreary left the dealership in a 2022 Kia K5. However, GLS subsequently

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concluded that the available information regarding McCreary’s income was not

sufficient to substantiate a loan in the requested amount and finalize approval for

her loan. In the absence of financing, McCreary’s vehicle was repossessed by the

dealership while she was at work on March 29, 2024.

{¶4} In the process of evaluating her legal options, McCreary discovered that

the registration for the name “Taylor Kia of Lima” had been cancelled by the Ohio

Secretary of State’s Office after Taylor Cadillac had failed to submit a renewal

application. In response, McCreary decided to register “Taylor Kia of Lima” in her

name. She then sent a cease and desist letter to Taylor Cadillac that addressed their

continued use of a fictitious name that was now registered to her.

{¶5} On June 28, 2024, McCreary filed a complaint that named Taylor

Cadillac and GLS as defendants. McCreary’s complaint alleged various violations

of the Consumer Sales Practices Act; demanded a return of funds from GLS; and

raised claims of fraud, conversion, and unjust enrichment. McCreary also requested

an injunction that would prohibit Taylor Cadillac from continuing to transact

business under the name “Taylor Kia of Lima” without her consent.

{¶6} On September 16, 2024, Taylor Cadillac and GLS filed a motion to

compel arbitration alongside a copy of an arbitration agreement that bore

McCreary’s signature. Taylor Cadillac submitted an affidavit from Nance that

averred he had reviewed this agreement with McCreary and placed an electronic

copy of her signature onto this document with her authorization. In response,

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McCreary filed an affidavit in which she indicated that she had signed the RBO but

denied authorizing Nance to place her electronic signature onto the arbitration

agreement. On October 3, 2024, the trial court granted Taylor Cadillac’s motion to

compel arbitration and dismissed the case without prejudice.

{¶7} McCreary filed her notice of appeal on October 31, 2024. On appeal,

she raises the following four assignments of error:

First Assignment of Error

The court erred in granting Defendants’ motion to enforce a binding arbitration agreement when Plaintiff disputed that the agreement was reviewed with Plaintiff or approved by her and that her signature was placed on the document without her knowledge or consent.

Second Assignment of Error

The court erred in granting Defendants’ motion to enforce a binding arbitration agreement allegedly entered into along with a contract for the purchase of a motor vehicle with Plaintiff using the unregistered fictitious name of Taylor Kia of Lima.

Third Assignment of Error

The court erred in granting Defendants’ motion to enforce a binding arbitration agreement on the separate claim against Taylor Cadillac Inc. for using the fictitious name of Taylor Kia of Lima after the name was registered to Plaintiff.

Fourth Assignment of Error

The court erred when it dismissed Appellant’s action submitting the parties to binding arbitration when the terms of the arbitration were unconscionable.

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Fifth Assignment of Error

The court erred in granting Defendants’ motion to enforce a binding arbitration agreement on claims filed against Global when it was never a party to any agreement or an assignee of any agreement.

{¶8} McCreary argues that the arbitration agreement is not enforceable

because she did not consent to having her signature placed on that agreement.

Legal Standard

{¶9} The General Assembly has embraced a public policy that favors

arbitration as promoting efficient dispute resolution and judicial economy. Hayes

v. Oakridge Home, 2009-Ohio-2054, ¶ 15-16, citing R.C. 2711.01(A). For this

reason, a strong presumption in favor of arbitration requires that “all doubts be

resolved in its favor.” Id. at ¶ 15. However, “a party cannot be required to submit

to arbitration any dispute which he has not agreed so to submit.” Estate of Myers v.

Healthcare Ventures of Ohio, LLC, 2023-Ohio-4254, ¶ 20 (3d Dist.), quoting

Academy of Medicine of Cincinnati v. Aetna Health, Inc., 2006-Ohio-657, ¶ 10.

{¶10} “The Ohio Arbitration Act allows for direct enforcement of arbitration

agreements through an order to compel arbitration under R.C. 2711.03 . . . .” Costin

v. Midwest Vision Partners, L.L.C., 2024-Ohio-463, ¶ 16 (8th Dist.). As the initial

step under this provision,

[t]he party aggrieved by the alleged failure of another to perform under a written agreement for arbitration may petition any court of

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common pleas having jurisdiction of the party so failing to perform for an order directing that the arbitration proceed in the manner provided for in the written agreement.

R.C. 2711.03(A). After hearing the parties on such a motion, the trial court is to

order the parties to proceed to arbitration “upon being satisfied that the making of

the agreement for arbitration or the failure to comply with the agreement is not in

issue. . . .” R.C. 2711.03(A).

{¶11} “If the making of the arbitration agreement or the failure to perform it

is in issue in a petition filed under . . . [R.C. 2711.03(A)], the court shall proceed

summarily to the trial of that issue.” R.C. 2711.03(B). See KeyBank, N.A. v. David,

2024-Ohio-5333, ¶ 42 (7th Dist.). “When determining whether a trial is necessary

under R.C. 2711.03(B) . . . , the relevant inquiry is whether a party has questioned

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