McKinney v. LaMalfa Party Ctr.

2022 Ohio 4333, 203 N.E.3d 57
CourtOhio Court of Appeals
DecidedDecember 5, 2022
Docket2022-L-023
StatusPublished
Cited by2 cases

This text of 2022 Ohio 4333 (McKinney v. LaMalfa Party Ctr.) 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
McKinney v. LaMalfa Party Ctr., 2022 Ohio 4333, 203 N.E.3d 57 (Ohio Ct. App. 2022).

Opinion

[Cite as McKinney v. LaMalfa Party Ctr., 2022-Ohio-4333.]

IN THE COURT OF APPEALS OF OHIO ELEVENTH APPELLATE DISTRICT LAKE COUNTY

BRIANNA MCKINNEY, CASE NO. 2022-L-023

Plaintiff-Appellee, Civil Appeal from the - vs - Painesville Municipal Court

LAMALFA PARTY CENTER, Trial Court No. 2021 CVF 00384 Defendant-Appellant.

OPINION

Decided: December 5, 2022 Judgment: Affirmed

Randy A. Vermilya, 41 East Erie Street, Suite 2, Painesville, OH 44077 (For Plaintiff- Appellee).

Monica R. Zibbel and Glenn E. Forbes, Forbes Law, LLC, 166 Main Street, Painesville, OH 44077 (For Defendant-Appellant).

CYNTHIA WESTCOTT RICE, J.

{¶1} Appellant, LaMalfa Party Center (“LaMalfa”), appeals the March 3, 2022

judgment of the Painesville Municipal Court adopting the February 25, 2022 Magistrate’s

Decision entering judgment in favor of appellee, Brianna McKinney. For the reasons set

forth herein, the judgment is affirmed.

{¶2} The parties entered into a contract for a wedding reception to be held on

October 31, 2020 at LaMalfa’s place of business. The contract expressly stated that no

terms of the contract could be changed once signed, and that monies paid as deposits

would not be refunded if the event was cancelled by either party for any reason. In February 2020, Ms. McKinney paid a deposit of $5,500 for the event, $500 of which was

paid to reserve the October 31, 2020 date.

{¶3} During the summer of 2020, Ms. McKinney contacted LaMalfa and

expressed her concerns regarding holding her reception during the COVID-19 pandemic;

she requested to reschedule her wedding date. LaMalfa denied her request and set forth

a series of COVID-19-related restrictions for the wedding reception, including but not

limited to mandating masks, social distancing, and changing the buffet meal stated in the

contract to a plated meal. The contract still required Ms. McKinney to have, and pay for,

a minimum of 120 guests. Ms. McKinney failed to provide LaMalfa with a final headcount

by the date set forth in the contract; by Ms. McKinney’s uncontradicted testimony, LaMalfa

cancelled the contract shortly thereafter, apparently in response to Ms. McKinney’s failure

to provide the required information. LaMalfa argues that it was at all relevant times ready,

willing, and able to perform its obligations under the contract, even with the COVID-19

mandates in place. According to Ms. McKinney, she got married on the original October

31, 2020 wedding date in her parents’ backyard with only her parents present.

{¶4} Ms. McKinney filed a claim against LaMalfa in the Mentor Municipal Court

for the return of her deposit but due to a conflict, the matter was transferred to the

Painesville Municipal Court, Small Claims Division. Upon LaMalfa’s motion, it was

transferred to the civil docket in the Painesville Municipal Court. The complaint filed by

Ms. McKinney alleged that LaMalfa wrongfully withheld her $5,500 deposit for a wedding

due to “impossibility of performance.” LaMalfa admitted withholding the deposit but

denied that the event was impossible and that the refusal to grant a refund was due to

impossibility of performance.

Case No. 2022-L-023 {¶5} A trial was held before a magistrate in December 2021. Ms. McKinney

testified that she understood the $500 deposit to save the date was forfeited, and that she

could have had the reception at LaMalfa on the original wedding date, but that she did

not want to risk her guests’ health. The magistrate ultimately found in favor of Ms.

McKinney, finding that LaMalfa materially breached the contract by adding the COVID-19

restrictions. LaMalfa filed a Motion for Findings of Fact and Conclusions of Law, which

the court issued in January 2022. LaMalfa also filed Objections to the Magistrate’s

Decision and supplemental objections, which Ms. McKinney opposed. The court adopted

the Magistrate’s Decision in March 2022 and entered judgment against LaMalfa in the

amount of $5,000 plus interest.

{¶6} It is from this judgment that LaMalfa now appeals, assigning four errors for

our review. Ms. McKinney did not file an appellee’s brief.

{¶7} “The standard of review generally employed to review a trial court’s

adoption of a magistrate’s decision is abuse of discretion.” Echols v. Echols, 11th Dist.

Geauga No. 2021-G-0040, 2022-Ohio-1719, ¶23, citing Degrant v. Degrant, 11th Dist.

Geauga Nos. 2019-G-0190 and 2019-G-0216, 2020-Ohio-70, ¶24. The term “abuse of

discretion” is one of art, “connoting judgment exercised by a court, which does not

comport with reason or the record.” State v. Underwood, 11th Dist. Lake No. 2008-L-113,

2009-Ohio-2089, ¶30, citing State v. Ferranto, 112 Ohio St. 667, 676-678 (1925). Stated

differently, an abuse of discretion is the “trial court’s ‘failure to exercise sound,

reasonable, and legal decision-making.’” Id., citing State v. Beechler, 2d Dist. Clark No.

09-CA-54, 2010-Ohio-1900, ¶62, quoting Black Law’s Dictionary (8 Ed.Rev.2004) 11.

Case No. 2022-L-023 “When a pure issue of law is involved in appellate review, the mere fact that the reviewing

court would decide the issue differently is enough to find error.” Beechler, supra, at ¶67.

{¶8} LaMalfa’s first assigned error states:

{¶9} The trial court erred and abused its discretion by adopting the Magistrate’s

finding of fact, where the Magistrate’s finding of fact was not based upon direct evidence

and was clearly erroneous.

{¶10} Under this assignment of error, LaMalfa specifically challenges the

magistrate’s finding of fact that Ms. McKinney “did not want her wedding to proceed with

the several changes that the LaMalfa made to the contract.” LaMalfa argues there is no

evidence to support this statement in the record. Instead, it argues the reason Ms.

McKinney stopped performance on her contractual obligations was because LaMalfa

would not change the date and she was concerned about putting her guests’ health at

risk due to COVID-19. Because this is a challenge to a factual determination, the issue

is whether the magistrate’s finding is supported by competent, credible evidence in the

record.

{¶11} Ms. McKinney testified that she could have had her wedding on October 31,

2020 at LaMalfa with the new policies and precautions that it put in place based on the

state COVID-19 mandates, but that she could not have invited as many people, and that

she did not want to put her guests’ health at risk.

{¶12} LaMalfa is technically correct; Ms. McKinney did not expressly testify that

she did not want to proceed with the reception because of the restrictions LaMalfa put in

place. However, the court’s statement was a reasonable inference from Ms. McKinney’s

testimony. She testified that she did not want to put her guests’ health at risk. Even with

Case No. 2022-L-023 the safety precautions LaMalfa put in place, Ms. McKinney would have had to invite, or

at least pay for, 120 guests. Furthermore, as discussed under the third assigned error,

the new COVID-19 procedures materially changed the contract. Thus, it was fair for the

court to conclude that Ms. McKinney did not wish to proceed under the restrictions that

LaMalfa put in place.

{¶13} Accordingly, LaMalfa’s first assigned error is without merit.

{¶14} Its second states:

{¶15} The trial court erred and abused its discretion by adopting the Magistrate’s

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Bluebook (online)
2022 Ohio 4333, 203 N.E.3d 57, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mckinney-v-lamalfa-party-ctr-ohioctapp-2022.