Parrish v. Jones

2013 Ohio 5224, 3 N.E.3d 155, 138 Ohio St. 3d 23
CourtOhio Supreme Court
DecidedDecember 4, 2013
Docket2012-0623
StatusPublished
Cited by36 cases

This text of 2013 Ohio 5224 (Parrish v. Jones) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Parrish v. Jones, 2013 Ohio 5224, 3 N.E.3d 155, 138 Ohio St. 3d 23 (Ohio 2013).

Opinions

[24]*24Lanzinger, J.

{¶ 1} We accepted this certified conflict to determine whether a trial court must consider the allegations set forth in the pleadings in addition to the opening statement when ruling on a motion for directed verdict made at the close of an opponent’s opening statement. We hold that although a trial court is not required to consider allegations contained in the pleadings when ruling on a motion for directed verdict made on the opening statement of an opponent, the pleadings may be used by the court in liberally construing the opening statement in favor of the party against whom the motion is made. We affirm the judgment of the court of appeals that reversed the granting of a directed verdict, albeit on different grounds.

I. Facts

{¶ 2} In 2005, appellee, Sandy Parrish (“Parrish”), the administrator of the estate of Karen Parrish, filed wrongful-death and survival actions in the Ross County Court of Common Pleas arising from the allegedly negligent care and death of Karen Parrish. Parrish alleged that on December 30, 2004, Karen was admitted to the Adena Regional Medical Center under the care of Michael Jones, D.O. Parrish further alleged that Dr. Jones had diagnosed Karen with an acute peripheral-nerve disorder. Karen was then transferred to a rehabilitation center, and during her stay there, appellant Christopher J. Skocik, D.O., was assigned to provide her medical care.

{¶ 3} In the complaint, Parrish alleged that the medical staff treating Karen had administered treatment negligently and, specifically, that they had failed to prescribe anticoagulation therapy; that they had failed to properly treat, diagnose, and monitor her; and that they had failed to timely respond with medical intervention. Parrish alleged that as a direct and proximate result of the negligence, Karen had suffered a premature death after experiencing cardiopulmonary arrest and hypoxia due to pulmonary emboli with saddle embolus and deep-vein thrombosis.

{¶ 4} Parrish’s complaint originally named as defendants Dr. Jones, Adena Regional Medical Center Corporation, Chillicothe Nursing and Rehabilitation [25]*25Center, L.L.C., and several John or Jane Does.1 In July 2006, the trial court granted Parrish leave to add appellants, Skocik and Family Medicine of Chilli-cothe, Inc. (“the Skocik defendants”), as new party defendants.

{¶ 5} The case proceeded to a jury trial in January 2011. At the close of Parrish’s opening statement, the Skocik defendants moved for directed verdict pursuant to Civ.R. 50, contending that Parrish had failed to meet the burden of establishing a case of medical malpractice against them because he had failed to set forth in his opening statement a standard of care, deviation from that standard, and causation.

{¶ 6} Parrish’s counsel had argued that the codefendant, Dr. Jones, would present expert testimony critical of Dr. Skocik: “Doctor Jones, through his attorneys, have hired a medical expert, Doctor Writ[e]sel who I had mentioned, who will tell you that it was Doctor Skocik’s fault. That it was Doctor Skocik’s fault for not ordering the proper D.V.T. prophylaxis in time. I’ll let Doctor Skocik’s attorneys argue for Doctor Skocik about that.”

{¶ 7} The trial court granted the motion for directed verdict and rendered judgment in favor of the Skocik defendants. The trial proceeded with Jones as the sole defendant, and the jury returned a verdict in favor of Jones.

{¶ 8} Parrish appealed and argued in part that the trial court had erred by failing to consider the complaint, along with the opening statement, in ruling on the motion for directed verdict. The Fourth District Court of Appeals reversed the trial court’s decision. The court of appeals held that the trial court was required to consider both the opening statement and the complaint before determining whether a directed verdict was appropriate. The court of appeals remanded the case for the trial court to revisit its ruling on the motion in light of the allegations made in the complaint.

{¶ 9} The Fourth District certified that its holding was in conflict with the holding of the Tenth District Court of Appeals in Blankenship v. Kennard, 10th Dist. Franklin No. 92AP-415, 1993 WL 318825 (Aug. 17, 1993). We determined that a conflict exists on the issue “ ‘[wjhether a trial court is required to consider the allegations contained in the pleadings, along with the opening statement, when ruling on a motion for a directed verdict made at the close of opening statement.’ ” 132 Ohio St.3d 1421, 2012-Ohio-2729, 969 N.E.2d 270.

II. Analysis

{¶ 10} This case presents us with an opportunity to clarify the standard a trial court should use in ruling on a motion for directed verdict made after an opening [26]*26statement. We hold that although the trial court is not required to consider the pleadings when ruling on a Civ.R. 50(A)(1) motion, in liberally construing the motion in favor of the opposing party, it may do so. We answer the certified question in the negative. We hold further that a trial court may grant a motion for directed verdict made at the close of a party’s opening statement only when that statement indicates that the party will be unable to sustain its cause of action or defense at trial.

A. Background of Civ.R. 50

{¶ 11} To address the present issues, we must first place Civ.R. 50(A) in its proper context among the civil rules that provide for the resolution of a case before the case reaches the jury. Different rules allow the termination of a case at different points in the litigation.

1. Civ.R 12: Motions to Dismiss and for Judgment on the Pleadings

{¶ 12} Civ.R. 12 provides for motions and pleadings to be made by a defendant after receiving a complaint, and Civ.R. 12(B) provides for the filing of a motion to dismiss based upon a failure to state a claim for relief:

Every defense, in law or fact, to a claim for relief in any pleading * * * shall be asserted in the responsive pleading thereto if one is required, except that the following defenses may at the option of the pleader be made by motion: * * * (6) failure to state a, claim upon which relief can be granted * * *. A motion making any of these defenses shall be made before pleading if a further pleading is permitted.

In addition to the Civ.R. 12(B)(6) pleading or motion, Civ.R. 12(C) provides for a motion for judgment on the pleadings: “After the pleadings are closed but within such time as not to delay the trial, any party may move for judgment on the pleadings.” If a party has pled or moved to dismiss under Civ.R. 12(B)(6) or moved for judgment on the pleadings under Civ.R. 12(C), Civ.R. 12(D) provides that the pleading or motion “shall be heard and determined before trial on application of any party.”

2. Civ.R 56: Summary Judgment

{¶ 13} Summary judgment pursuant to Civ.R. 56 is another method available to a party seeking to avoid a trial and is used when the facts of a case are allegedly undisputed. A motion for summary judgment is based on evidence presented to the court and allows consideration of facts beyond the allegations included in the pleadings:

[27]

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Cite This Page — Counsel Stack

Bluebook (online)
2013 Ohio 5224, 3 N.E.3d 155, 138 Ohio St. 3d 23, Counsel Stack Legal Research, https://law.counselstack.com/opinion/parrish-v-jones-ohio-2013.