Oehler v. McAdams

2019 Ohio 1976
CourtOhio Court of Appeals
DecidedMay 22, 2019
Docket28903
StatusPublished
Cited by2 cases

This text of 2019 Ohio 1976 (Oehler v. McAdams) 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
Oehler v. McAdams, 2019 Ohio 1976 (Ohio Ct. App. 2019).

Opinion

[Cite as Oehler v. McAdams, 2019-Ohio-1976.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF SUMMIT )

SCOTT N. OEHLER C.A. No. 28903

Appellee

v. APPEAL FROM JUDGMENT ENTERED IN THE PAT MCADAMS, et al. COURT OF COMMON PLEAS COUNTY OF SUMMIT, OHIO Appellees CASE No. CV-2016-03-1490

and

DANIEL S. WHITE

Appellant

DECISION AND JOURNAL ENTRY

Dated: May 22, 2019

SCHAFER, Presiding Judge.

{¶1} Appellant, Attorney Daniel S. White, appeals the judgment of the Summit County

Court of Common Pleas granting sanctions against him. For the reasons that follow, we affirm.

I.

{¶2} Defendants-Appellees, Pat and Rebecca McAdams (“the McAdamses”), and

Plaintiff-Appellee, Scott Oehler, entered into a real estate purchase agreement. The record

shows that the McAdamses purchased the property at issue as an investment and that, during the

approximately eight months they owned the property, never lived there. The McAdamses made

various repairs and improvements to the property before selling it to Mr. Oehler in March 2015,

including the replacement of a downspout pipe with a perforated pipe and the addition of gravel 2

and grading around the property. Mr. McAdams also painted the basement with an oil based

primer, which was not designed to resist moisture or seal the block.

{¶3} The parties entered into a real estate purchase agreement that provided that Mr.

Oehler would purchase the property in its “as is” condition contingent upon his good faith

satisfaction with the results of a home inspection. The McAdamses indicated on the residential

disclosure form which they provided to Mr. Oehler that they were not aware of any previous or

current water leakage, water accumulation, excess moisture, or other defects to the property and

denied any knowledge of any previous or current flooding, drainage, settling or grading or

erosion problems on the property. The McAdamses did, however, disclose on the form that there

had previously been a brick veneer on the front of the home that allowed water to run behind and

enter the foundation. Mr. Oehler hired a home inspector to perform a general home inspection

which indicated no detection of moisture in the basement of the property or any relevant issues.

{¶4} After a few months of owning the property with no issue, Mr. Oehler experienced

a flooding event in the basement following an unusually heavy rainfall for several days. Mr.

Oehler subsequently contacted several basement waterproofing companies in an effort to

remediate the issues caused by the water intrusion. Ohio State Waterproofing provided Mr.

Oehler with an estimate to install a water-proofing system in the basement which was the highest

of all the estimates Mr. Oehler received and almost twice as much as the lowest estimate.

Although no subsequent flooding event occurred at the property, Mr. Oehler hired Ohio State

Waterproofing to install a water-proofing system more than six months later.

{¶5} Mr. Oehler thereafter filed the complaint in this matter, through Attorney White,

alleging fraudulent disclosure, fraudulent inducement, and mutual mistake of fact. The

complaint sought damages related to the installation of a water-proofing system in the basement 3

of the property. The McAdamses answered the complaint and the matter proceeded through the

pretrial process. The McAdamses issued discovery requests and deposed both Mr. Oehler and an

Ohio State Waterproofing foreman. Attorney White did not issue any discovery on behalf of his

client prior to the discovery deadline nor did he depose the McAdamses or their expert.

{¶6} The McAdamses eventually filed a motion for summary judgment on all of Mr.

Oehler’s claims. Mr. Oehler responded to the motion through Attorney White and the

McAdamses thereafter filed a response in support of their motion. The trial court ultimately

granted the McAdamses’ motion, entering judgment in their favor and against Mr. Oehler on all

claims in the complaint. In doing so, the trial court determined that Mr. Oehler could point to no

evidence that any water infiltration had occurred prior to the sale other than that which the

McAdamses disclosed on the property disclosure form. The trial court further found that Mr.

Oehler had failed to establish that any defects related to water or mold existing prior to the sale

of the property or the June flooding event. Finally, the trial court found that Mr. Oehler had

failed to present any evidence that the McAdamses were aware of any prior instances of water

intrusion or damage, let alone that the McAdamses had concealed such defects and/or

intentionally misled Mr. Oehler about any such defects.

{¶7} The McAdamses thereafter filed a motion for sanctions, pursuant to R.C. 2323.51

and Civ.R. 11, asserting that they were entitled to an award of reasonable attorney fees and costs

incurred for opposing the frivolous filing and prosecution of the lawsuit, specifically stating the

following:

Attorney White and Mr. Oehler filed and prosecuted this suit knowing that their allegations were without evidentiary support and not warranted under existing law. McAdamses’s [sic] counsel believes that the suit was filed as part of an assembly line process developed by Attorney White and his expert witness, Ohio State Waterproofing * * *, without regard to the merits of this case. 4

Mr. Oehler, through Attorney White, argued in his response that sanctions were not appropriate

in this matter. At the sanctions hearing, the McAdamses elicited testimony from both Attorney

White and Mr. Oehler. Attorney White did not present any testimony.

{¶8} The trial court ultimately determined that Attorney White had engaged in

frivolous conduct when he initiated and maintained the litigation in this case and granted the

McAdamses’ motion for sanctions, determining that an award of attorney fees was appropriate.

The trial court then set the matter for a hearing to determine the amount of the award.

Thereafter, Attorney White filed a motion for leave to withdraw as counsel for Mr. Oehler, citing

Mr. Oehler’s request that Attorney White no longer represent him in this matter. Although the

trial court granted Attorney White’s motion, the court stated in its order both Attorney White and

Mr. Oehler were still required to attend the later hearing.

{¶9} The trial court subsequently ordered that the matter be assigned to a magistrate for

resolution and disposition. Following the hearing on sanctions, the magistrate issued a decision

finding that damages should be awarded against Attorney White only for his actions and not

against Mr. Oehler. The magistrate further found that the McAdamses were entitled to an award

of $37,185.89 consisting of attorney fees and expenses incurred as a result of litigating the

present matter as a result of Attorney White’s frivolous conduct. The trial court thereafter

adopted the magistrate’s decision and rendered judgment in favor of the McAdamses and against

Attorney White in the amount of $37,185.89.

{¶10} Attorney White filed this timely appeal, raising three assignments of error for our

review. As assignments of error two and three raise similar issues, we elect to address them

together. 5

II.

Assignment of Error I

The trial court’s decision to grant [the McAdamses]’ motion for sanctions against [Attorney White] constitutes reversible error.

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