Owens v. Purcel

2024 Ohio 1514, 242 N.E.3d 142
CourtOhio Court of Appeals
DecidedApril 19, 2024
DocketL-23-1152
StatusPublished
Cited by2 cases

This text of 2024 Ohio 1514 (Owens v. Purcel) 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
Owens v. Purcel, 2024 Ohio 1514, 242 N.E.3d 142 (Ohio Ct. App. 2024).

Opinion

[Cite as Owens v. Purcel, 2024-Ohio-1514.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT LUCAS COUNTY

Norma Owens Court of Appeals No. L-23-1152

Appellant Trial Court No. CI0202204695

v.

Jerry Purcel DECISION AND JUDGMENT

Appellee Decided: April 19, 2024

*****

Steven L. Crossmock and Stevin J. Groth, for appellant.

David R. Hudson, Taylor C. Knight, and Jordan R. Messmer, for appellee.

***** MAYLE, J.

{¶ 1} Plaintiff-appellant, Norma Owens, appeals the May 30, 2023 judgment of

the Lucas County Court of Common Pleas, granting judgment on the pleadings in favor

of defendant-appellee, Jerry Purcel. For the following reasons, we affirm the trial court

judgment. I. Background

{¶ 2} Norma Owens was struck by an automobile on December 30, 2014, when

she was 16 years old. Under R.C. 2305.10(A), an action for bodily injury must be

brought within two years after the cause of action accrues. However, because Owens was

under 18 at the time of the accident, the statute of limitations tolled until she reached the

age of majority, on March 17, 2016. R.C. 2305.16. She, therefore, had until March 17,

2018, by which to file a complaint against the driver of the vehicle that struck her. The

driver died on April 2, 2017. On March 4, 2019, attorney Jerry Purcel filed a personal

injury suit on Owens’s behalf in Toledo Municipal Court. The case was dismissed

without prejudice on October 8, 2019, for failure to perfect service of process.

{¶ 3} Owens sued Purcel for legal malpractice on August 21, 2020. She

voluntarily dismissed her complaint on December 28, 2021, and refiled under the saving

statute, R.C. 2305.19, on December 21, 2022. Purcel answered and filed a motion for

judgment on the pleadings under Civ.R. 12(C), arguing that the action was time-barred

under the legal-malpractice statute of repose, R.C. 2305.117(B).

{¶ 4} The trial court granted Purcel’s motion. It found that the act or omission

giving rise to Owens’s claim of legal malpractice was Purcel’s failure to file a complaint

before the statute of limitations expired on March 17, 2018. It concluded that under R.C.

2305.117(B), the statute of repose lapsed March 18, 2022, four years after Purcel failed to

timely file a complaint. Because Owens’s legal-malpractice action was refiled more than

2. four years later, on December 21, 2022, the court held that it was barred by the statute of

repose and dismissed Owens’s complaint.

{¶ 5} Owens appealed. She assigns the following error for our review:

I. THE TRIAL COURT ERRED IN DETERMINING THAT MARCH

18, 2018, IS THE DATE UPON WHICH NORMA’S LEGAL

MALPRACTICE FOUR-YEAR STATUTE OF REPOSE PERIOD

STARTED AGAINST JERRY PURCEL[.]

a. THE TRIAL COURT FAILED TO PROPERLY CONSIDER

THAT STATUTE OF LIMITATION IS AN AFFIRMATIVE

DEFENSE[.]

b. THE FAILURE TO PERFECT SERVICE IS THE DATE OF

THE OCCURRENCE OF THE ACT OR OMISSION GIVING

RISE TO MS. OWEN’S CLAIM[.]

II. Law and Analysis

{¶ 6} Owens argues that the trial court misapplied R.C. 2305.117(B) because it

used the wrong triggering event for calculating when the legal-malpractice statute of

repose expired. Owens denies that the act constituting legal malpractice was the failure

to timely file suit under R.C. 2305.10. She maintains that the relevant event triggering

the statute of repose was either (1) March 4, 2019, the date the personal-injury complaint

was filed in Toledo Municipal Court; (2) March 4, 2020, the end of the one-year period

within which service of the complaint needed to be perfected; or (3) October 8, 2019,

3. when the municipal court dismissed the complaint for failure to perfect service within six

months. She insists that using any one of these triggering events, her legal-malpractice

action was filed before the four-year statute of repose expired, on either March 4, 2023,

March 4, 2024, or October 8, 2023.

{¶ 7} Purcel responds that the act or omission giving rise to Owens’s legal-

malpractice claim was the failure to timely file her personal-injury action, thus her legal-

malpractice claim accrued on the date the statute of limitations expired, not the date that

Purcel eventually filed the untimely action. Purcel maintains that the failure to perfect

service had no impact on the timeliness of the personal-injury lawsuit.

A. Standard of Review

{¶ 8} Under Civ.R. 12(C), “[a]fter the pleadings are closed but within such time as

not to delay the trial, any party may move for judgment on the pleadings.” In considering

a Civ.R. 12(C) motion, the trial court may review only “the complaint and the answer as

well as any material incorporated by reference or attached as exhibits to those pleadings.”

Walker v. City of Toledo, 2017-Ohio-416, ¶ 19 (6th Dist.).

{¶ 9} Employing the same standard as a Civ.R. 12(B)(6) motion for failure to state

a claim upon which relief may be granted, the trial court must construe as true the

material allegations in the complaint and draw all reasonable inferences in favor of the

nonmoving party. Id. at ¶ 18, citing McMullian v. Borean, 2006-Ohio-3867, ¶ 7 (6th

Dist.); Ohio Manufacturers’ Assn. v. Ohioans for Drug Price Relief Act, 2016-Ohio-

3038, ¶ 10, citing Rayess v. Educational Comm. for Foreign Med. Graduates, 2012-

4. Ohio-5676, ¶ 18. If it appears from the pleadings and the materials incorporated by

reference or attached as exhibits that the nonmoving party can prove no set of facts

entitling it to relief, the trial court may dismiss the plaintiff’s claims under Civ.R.

12(C). Ohio Manufacturers’ Assn. at ¶ 10. We review the trial court’s judgment de

novo. Reister v. Gardner, 2020-Ohio-5484, ¶ 17.

B. The Legal-Malpractice Statutes of Limitation and Repose

{¶ 10} Under R.C. 2305.11(A), an action for legal malpractice against an attorney

must be commenced within one year after the cause of action accrued. The Ohio

Supreme Court has applied a discovery rule to legal-malpractice claims, however.

Zimmie v. Calfee, Halter & Griswold, 43 Ohio St.3d 54, 57 (1989). Under that discovery

rule, “an action for legal malpractice accrues and the statute of limitations begins to run

when there is a cognizable event whereby the client discovers or should have discovered

that his injury was related to his attorney’s act or non-act and the client is put on notice of

a need to pursue his possible remedies against the attorney or when the attorney-client

relationship for that particular transaction or undertaking terminates, whichever occurs

later.” Id. at syllabus.

{¶ 11} In addition, effective June 2, 2021, the legislature enacted a statute of

repose, R.C. 2305.117(B), applicable to legal-malpractice claims. Statutes of limitations

and statutes of repose both limit the time for bringing a claim, but they operate differently

and target different actors. Wilson v. Durrani, 2020-Ohio-6827, ¶ 9-10. “A statute of

limitations establishes ‘a time limit for suing in a civil case, based on the date when the

5. claim accrued (as when the injury occurred or was discovered).’” Id. at ¶ 9, quoting

Black’s Law Dictionary 1707 (11th Ed.2019). It “operates on the remedy, not on the

existence of the cause of action itself.” Id., citing Mominee v. Scherbarth, 28 Ohio St.3d

270, 290 (1986), fn. 17 (Douglas, J., concurring).

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Bluebook (online)
2024 Ohio 1514, 242 N.E.3d 142, Counsel Stack Legal Research, https://law.counselstack.com/opinion/owens-v-purcel-ohioctapp-2024.