Nemeth v. Bittikofer

124 N.E.2d 467, 69 Ohio Law. Abs. 87, 2 Ohio Op. 2d 208, 1953 Ohio Misc. LEXIS 321
CourtCuyahoga County Common Pleas Court
DecidedNovember 13, 1953
DocketNo. 648957
StatusPublished
Cited by2 cases

This text of 124 N.E.2d 467 (Nemeth v. Bittikofer) is published on Counsel Stack Legal Research, covering Cuyahoga County Common Pleas Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nemeth v. Bittikofer, 124 N.E.2d 467, 69 Ohio Law. Abs. 87, 2 Ohio Op. 2d 208, 1953 Ohio Misc. LEXIS 321 (Ohio Super. Ct. 1953).

Opinion

OPINION

By THOMAS, J:

On March 18, 1953, plaintiff Nemeth sued defendant Bittikofer in this court. She says that she suffered personal injuries in an accident on November 17, 1952, which involved an automobile-driven by herself and an automobile operated by Bittikofer. Claiming that she was hurt by reason of Bittikofer’s negligence in operating his automobile, she prays for $5,000.00.

Afterwards on May 5, 1953, in the Municipal Court of Lakewood Bittikofer sued Nemeth for damage to his automobile growing out of the above accident. Claiming that Nemeth was negligent in operating her automobile, he seeks $795.00.

In this present action for injunctive relief plaintiff prays that

“defendant be enjoined from prosecuting his suit in the Municipal Court of Lakewood until the case filed earlier in the Court of Common Pleas is reduced to a final judgment; in the alternative, plaintiff prays that this Court order defendant to consolidate his Lakewood Municipal Court (case) with the earlier filed case in the Court of Common Pleas, or to file a Cross petition to said suit in this Court of Common Pleas and dismiss his action in Lakewood.”

It will become evident that the Municipal Court has jurisdiction to hear and determine the Bittikofer case and that [89]*89this court has jurisdiction to adjudicate the Nemeth case.

Nemeth’s claim for $5,000.00 in damages is within the jurisdiction of this court. It exceeds the $2000.00 limit of civil jurisdiction of the Municipal Court of Lakewood. Her claim therefore cannot be prosecuted in the Municipal Court of Lakewood either as an original action or as a cross petition.

Bittikofer’s claim for $795.00 in damages is within the jurisdiction of either court. He is entitled to file his claim as an original action in the Municipal Court of Lakewood or as an original action in this court. He may also file it as a cross petition in Nemeth’s action, but he is not bound to, since the filing of a counterclaim is permissive not obligatory Bittikofer’s privilege to choose between this court and the Municipal Court of Lakewood as the forum in which to sue Nemeth is the combined product of several statutes. It would be contrary to law and beyond the power of this court to order the defendant to consolidate his Municipal Court action with Nemeth’s action in this court or to require Bittikofer to file a cross petition in Nemeth’s action.

But granted that the Municipal Court of Lakewood has jurisdiction to hear and determine the Bittikofer case there still remains to be decided the question posed by counsel, namely:

“Whether or not Nemeth, the plaintiff in the Common Pleas case, can enjoin Bittikofer from prosecuting his subsequently filed suit in Lakewood Municipal Court until such time as the Common Pleas case has been determined.”

To answer that question it must be first determined whether there is a common subject of litigation in these two pending actions over which the Municipal'Court of Lakewood has concurrent jurisdiction, the exercise of which may deprive or interfere with this court’s hearing and determining Nemeth’s action.

To recover a judgment in her action in this court, Nemeth must establish that Bittikofer negligently caused their collision.

To recover a judgment in his action in Municipal Court of Lakewood, Bittikofer must establish that Nemeth negligently caused their collision.

Defendant in each case (plaintiff in the other easel is relying on a general denial but will undoubtedly couple with it the defense of the other party’s contributory negligence.

Thus the outcome in each case will depend on whether under the proved facts the collision of November 17, 1952, was caused by negligence of Bittikofer, of Nemeth, or of both.

It is a matter of general knowledge to be judicially noted [90]*90that under present circumstances a civil case comes up for trial sooner in the Municipal Court of Lakewood than in this court. Hence in the ordinary course of events it may be expected that Bittikofer’s case in Municipal Court will be tried first.

If Bittikofer secures a judgment against Nemeth in the Municipal Court it will be an adjudication that Nemeth negligently caused their collision thereby rendering her guilty of contributory negligence as a matter of law in her action in this court against Bittikofer.

If Bittikofer loses in Municipal Court a special finding in that case by the jury or the judge that both Nemeth and Bittikofer were guilty of negligence combining to cause their collision would likewise estop and foreclose Nemeth from prevailing in her action in this court.

It follows that a prior trial of Bittikofer’s case in Municipal Court may cast an indelible shadow upon Nemeth’s action in this court. It can predetermine the judgment in her case.

In an effort to protect its prior but concurrent jurisdiction over the common subject of litigation, this court might advance Nemeth’s action ahead of the trial of the Bittikofer action in Municipal Court.

But Bittikofer might counter the acceleration of Nemeth’s action by securing an earlier advancement of his action in Municipal Court, only to possibly precipitate an earlier advancement in this court’s case. In such a tug of war the only prizes would be wasteful duplication of proceedings, increased expense, confusion and perhaps even judicial anarchy.

It is thus seen that in the Bittikofer action the Municipal Court of Lakewood obtained concurrent jurisdiction over the fundamental subject of negligence pre-existing in the Nemeth action. It is obvious too that the jurisdiction of this court, though it attached earlier, may be completely defeated if Bittikofer’s case is tried first.

Such conflict of jurisdiction should be resolved in accordance with

“the settled law of this state that among courts having concurrent jurisdiction of any given subject-matter the court whose jurisdiction rightfully first attaches shall exercise and continue that jurisdiction free from any interference by any other court having a like jurisdiction.” Addams v. State, ex rel., 104 Oh St 475.

However it is contended that this settled rule of comity, so necessary to avoid collisions between courts, only applies between courts of coextensive or co-ordinate jurisdiction, and does not control the present conflict of jurisdiction be[91]*91tween a court of general powers and a court of limited authority.

In support of this argument, counsel for the defendant relies on State, ex rel. McHenry, v. Calhoun, 87 Oh Ap 1, wherein our Court of Appeals recently denied a writ to prohibit a justice of peace “from hearing and determining an action for damages to property that could have been asserted as a counterclaim in action pending in the Common Pleas Court between the same parties in which the plaintiff in Common Pleas Court sought recovery of damages for injuries to person and property in an amount in excess of the jurisdiction of the justice.”

Several conclusions there announced require examination.

In its opinion the court quoted with approval the following statement from 11 O. Jur., 726, Section 81:

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Cite This Page — Counsel Stack

Bluebook (online)
124 N.E.2d 467, 69 Ohio Law. Abs. 87, 2 Ohio Op. 2d 208, 1953 Ohio Misc. LEXIS 321, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nemeth-v-bittikofer-ohctcomplcuyaho-1953.