Mramor v. Chapman

488 N.E.2d 1257, 22 Ohio Misc. 2d 8, 22 Ohio B. 182, 1984 Ohio Misc. LEXIS 216
CourtLake County Court of Common Pleas
DecidedJanuary 12, 1984
DocketNo. 82 CIV 0784
StatusPublished

This text of 488 N.E.2d 1257 (Mramor v. Chapman) is published on Counsel Stack Legal Research, covering Lake County Court of Common Pleas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mramor v. Chapman, 488 N.E.2d 1257, 22 Ohio Misc. 2d 8, 22 Ohio B. 182, 1984 Ohio Misc. LEXIS 216 (Ohio Super. Ct. 1984).

Opinion

Mitrovich, J.

The within matter is a motion for prejudgment interest filed by plaintiff pursuant to R.C. 1343.03(C). The plaintiff requests prejudgment interest upon a money judgment rendered by a jury on November 17, 1983, in the amount of $15,000. The matter was tried on a claim of medical malpractice.

The statute provides prejudgment interest against the judgment debtor if a good faith effort to settle the case was not made. Two cases are presented for consideration of the court: Holmes v. Lombardo Investment Builders (Feb. 1, 1983), Cuyahoga C.P. No. 996531, unreported, and Ware v. Richey (1983), 14 Ohio App. 3d 3. Both decisions attempt in some measure to define the phrase, “* * * failed to make a good faith effort to settle the case * * *.” Each court views the alleged lack of “good faith” in the negative and derogatory sense. These courts hold there must be the presence of “insincerity,” “dishonesty” or “duplicity,” and the manner of applying these terms is akin to evil motive or intent. If these elements are not present, claimant has not shown lack of good faith.

Every litigant has a right to avail himself of all the benefits of the judicial system. One benefit is to require the claimant to prove before a jury that which he claims. Such a litigant is not obligated to settle the matter without his day in court and, in line with this, R.C. 1343.03(B) only requires interest to be paid from the date of judgment. The legislature has, however, carved out an exception in R.C. 1343.03(C), which requires a showing of bad faith. What then must the claimant prove to be entitled to prejudgment interest?

The recognition of the concept of prejudgment interest by the legislature is one of economics. The legislature may or may not have intended that prejudgment interest act as a penalty for failure to reasonably settle a case without trial. If the definition of “good faith,” or its opposite, “bad faith,” is in the negative or derogatory sense, then it can reasonably be concluded it was intended to penalize the user of bad faith. Obviously, if this were the purpose of the legislature, the public policy would be that all litigants are given fair warning to approach their causes of action and defenses in such a fashion as to recognize one’s obligations, make a fair analysis of them and settle the issues without court intervention. Such public policy would have the obvious effects of reducing litigation, reducing crowded and overworked trial court dockets and courts of appeals dockets, as well as resolving rapidly the issues of the community so the parties can go about their business. [9]*9Nothing in this opinion should be construed as this court condoning the attitude that any litigant be prevented from exercising any right or privilege he may have under the law and Constitution of this state. However, the litigant ought to have some direct responsibility for the manner in which he chooses to conduct his case.

If the concept of penalty is discounted, and economic aspects are addressed, a much different view is apparent. Trial practitioners are well aware that the judicial process which aspires to the full and reasonable litigation of every claim and corresponding defense is, by its very nature, a potential source of abuse. Forcing a claimant with a legitimate and real cause of action to file a claim in court, expend large sums of money to hire attorneys, prepare experts, take depositions, etc., has the effect of driving up the cost of justice. High costs and large pretrial outlays are hardly conducive to a “fair” system of administering the judicial process. Many litigants are keenly aware of the growing costs of litigation and directly rely upon the economic realities to force lower settlements as the legal system more and more becomes a rich man’s tool.

In the case at bar, the defendant was a physician who had performed a surgical procedure upon the plaintiff by cauterizing her fallopian tubes. Two years later, a tubal pregnancy resulted, causing a bursting of a fallopian tube. Internal hemorrhaging occurred, necessitating an operation, whereupon plaintiffs abdominal cavity was opened and the tube removed and the damage repaired. The operative report which the plaintiff produced to the defendant at the outset of the case indicated a substantial basis to believe that the tube in question had not been properly cauterized. The report indicated the tube was open, thus accounting for the pregnancy. The more than reasonable inference to be drawn was that the defendant-doctor failed to perform the medical procedure properly and therefore was negligent.

During the pretrials, defendant refused to make any reasonable offer of settlement, not even the standard “nuisance value offer,” often made to dispose of cases when the defendant feels no liability exists, but does not wish to expend the funds to completely defend the case.

The case at bar was defended by the defendant’s insurance company, which, in reality, made the decision against offers of settlement and decided to litigate the matter to a jury. The policy of insurance does not require the insured to concur in the settlement; however, the defendant was adamant that he had not been negligent in performing the surgical procedure. The plaintiff contends as a result of the insurance company’s lack of desire to make a meaningful offer.of settlement, she was required to expend $11,952 for expert fees, depositions, attorney fees, and other costs, retaining $3,057.33 out of a judgment of $15,000. This is contrasted by some of the defendant’s expert witnesses’ testimony that they were not charging the defendant an expert fee.

Plaintiff has won a hollow victory. She has brought her cause of action to an impartial tribunal, but to prevail, was required to expend almost her entire judgment. Such a result is not only bad economics, it is not even one in which the victor can feel justice was done.

One can argue that the decision was for the plaintiff to make regarding whether or not the economics justified the suit. The plaintiff could have avoided the large expenditure of funds by settling the matter. The insurance company on the other hand did not offer either $3,057.33 or the nuisance cost, or the cost of the medical expenses, as is sometimes customary in settlement of litigation.

[10]*10Defendant’s counsel has indicated to the court that the insurance company had instructed him to go forward with the suit and now that it has lost, to file an appeal. Certainly an appeal will swiftly reduce the lion’s share of $3,057.33, leaving plaintiff with nothing for her injury even if she prevails. If the case is thereafter appealed, or reversed and remanded, plaintiff will be required to suffer further loss. No matter what the perspective, the result is unjust and unfair. Obviously, the jury had no knowledge that plaintiff was to realize $3,000 on the judgment. The results certainly would have been different if they were entitled to that knowledge.

The law in Ohio is such that plaintiff may not recover unless and until an expert testifies to support the claim. The law requires an extreme monetary burden without any view to reimbursement for the cost of the litigation. While the plaintiff is being forced to face the expenditure of funds, the insurance company is lawfully able to retain its monies and can invest them to realize a profit.1 During the period of litigation, plaintiff is denied the use of the funds which the evidence indicates she had a reasonable prospect of obtaining.

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Related

Ware v. Richey
469 N.E.2d 899 (Ohio Court of Appeals, 1983)

Cite This Page — Counsel Stack

Bluebook (online)
488 N.E.2d 1257, 22 Ohio Misc. 2d 8, 22 Ohio B. 182, 1984 Ohio Misc. LEXIS 216, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mramor-v-chapman-ohctcompllake-1984.