Phillips v. Independence

2025 Ohio 5511
CourtOhio Court of Appeals
DecidedDecember 11, 2025
Docket114685
StatusPublished

This text of 2025 Ohio 5511 (Phillips v. Independence) 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
Phillips v. Independence, 2025 Ohio 5511 (Ohio Ct. App. 2025).

Opinion

[Cite as Phillips v. Independence, 2025-Ohio-5511.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

JEFFREY PHILLIPS, :

Plaintiff-Appellant, : No. 114685 v. :

CITY OF INDEPENDENCE, :

Defendant-Appellee. :

_____________

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED RELEASED AND JOURNALIZED: December 11, 2025

Civil Appeal from the Cuyahoga County Court of Common Pleas Case No. CV-23-986133

Appearances:

Michael Shaut & Associates, LPA, and Michael Shaut, for appellant.

Taft, Stettinius & Hollister LLP, Gregory J. O’Brien, City of Independence Law Director, and Jack Miab, for appellee.

WILLIAM A. KLATT, J.:

Plaintiff-appellant Jeffrey Phillips (“Phillips”) appeals from the trial

court’s December 13, 2024 judgment entry granting defendant-appellee City of

Independence’s (“the city” or “Independence”) motion for summary judgment based on political-subdivision immunity under R.C. Ch. 2744. For the following

reasons, we affirm.

Factual and Procedural History

This case stems from a motor vehicle accident that occurred on

October 5, 2021. That morning, Phillips was driving down Brecksville Road in

Independence, Ohio, when his vehicle left the road, hit the shoulder of the road, and

hit a mailbox and temporary fencing that had been installed on the west side of

Brecksville Road. Phillips’s vehicle drove through the temporary fence and partially

into a steep embankment. A steel rod from the temporary fencing penetrated

Phillips’s windshield, striking Phillips in the head and causing him to lose

consciousness and suffer severe head and brain trauma.

On September 27, 2023, Phillips filed a complaint against

Independence, alleging one count of deliberate indifference and one count of

negligence related to the conditions surrounding the accident.

On November 27, 2023, the city filed an answer and motion to

dismiss.

On January 24, 2024, Phillips filed a motion for leave to file an

amended complaint. On February 2, 2024, Phillips filed a motion for leave to file a

second amended complaint instanter with the city’s consent; the trial court granted

this motion. The second amended complaint added Elizabeth Hrovat (“Hrovat”),

State Farm Insurance Company (“State Farm”), Gauis S. Vaduva (“Vaduva”), and

Rachel Veronica (“Veronica”) as new-party defendants. The second amended complaint alleged that the accident occurred on the property of Hrovat, Vaduva, and

Veronica and the fence at issue was also located on their property. None of the

additional defendants are a party to the instant appeal.

On October 1, 2024, the city filed a motion for summary judgment,

arguing that summary judgment was appropriate because the city was entitled to

the statutory immunity reserved for political subdivisions in Ohio pursuant to

R.C. 2744.02.

On October 29, 2024, Phillips filed a brief in opposition to the city’s

motion for summary judgment. On November 5, 2024, the city filed a reply brief in

support of its motion for summary judgment.

On December 13, 2024, the court granted the city’s motion for

summary judgment.

Phillips appealed. He now raises four assignments of error for our

review:

I. The trial court erred by failing to address an integral question regarding the ownership of the original fence which caused the Appellant’s substantial injuries.

II. The trial court erred in its grant of summary judgment against Appellant’s claims against when the manifest weight of the evidence demonstrated an applicable exception to Appellee’s claim of political immunity under R.C. 2744.02(b)(2).

III. The trial court erred in its grant of summary judgment against Appellant’s claims when the manifest weight of the evidence demonstrated an applicable exception to political immunity under R.C. 2744.02(b)(4).

IV. The trial court erred in its grant of summary judgment against Appellant’s claims given uncontroverted expert evidence that the failure to maintain the roadway was the actual cause of the Appellant’s leaving the roadway which led to his injuries, which is an exception to political immunity under R.C. 2744.02(b)(3).[1]

Law and Analysis

R.C. Ch. 2744 sets forth a comprehensive statutory scheme for the tort

liability of political subdivisions and their employees. It establishes a three-step

analysis for determining whether a political subdivision is immune from liability,

starting with a broad rule that a political subdivision is generally not liable in

damages. Supportive Solutions, L.L.C. v. Electronic Classroom of Tomorrow,

2013-Ohio-2410, ¶ 11, citing Greene Cty. Agricultural Soc. v. Liming, 2000-Ohio-

486, ¶ 25, and R.C. 2744.02(A)(1).

The three-tier analysis provides:

Under the first tier of analysis, if a defendant is determined to be a political subdivision, it is immune from liability for its governmental and proprietary functions in a civil action for injury, death, or loss to person or property allegedly caused by any act or omission of the political subdivision or an employee of the political subdivision . . . .” [R.C. 2744.02(A)(1).]

Under the second tier, the immunity conferred under R.C. 2744.02(A)(1) “‘is not absolute, but is . . . subject to the five exceptions to immunity listed in . . . R.C. 2744.02(B).’” Hortman [v. Miamisburg, 2006-Ohio-4251,] ¶ 14, quoting Cater [v. Cleveland, 1998-Ohio-421.]

The third tier of political subdivision immunity analysis comes into operation if it is determined that one of the exceptions to immunity under R.C. 2744.02(B)(1) through (5) applies. Under the third tier, immunity can be reinstated if the political subdivision can demonstrate that one of the defenses under R.C. 2744.03 applies.

1 In Phillips’s statement of his assignments of error in his opening brief, he presents

his assignments of error in this order. In the body of his brief, he presents them in a different order. For clarity, we will refer to the assignments of error as they are numbered here. Berner v. New Leaf Residential Servs., 2024-Ohio-1788, ¶ 14-16.

Thus, in the first tier of the analysis, the court applies the general rule

provided in R.C. 2744.02(A)(1) that a political subdivision is immune. Goldfarb v.

Cuyahoga Cty., 2025-Ohio-3283, ¶ 20. “The second tier of the analysis places the

burden on the plaintiff to overcome this statutory immunity by showing that one of

the five exceptions contained in R.C. 2744.02(B) applies.” Id., citing Powell v.

Cleveland, 2022-Ohio-4286, ¶ 10 (8th Dist.).

“‘Whether a party is entitled to immunity is a question of law properly

determined by the court prior to trial pursuant to a motion for summary judgment.’”

McConnell v. Dudley, 2019-Ohio-4740, ¶ 17, quoting Pelletier v. Campbell, 2018-

Ohio-2121, ¶ 12, citing Conley v. Shearer, 1992-Ohio-133.

We review summary judgment rulings de novo, applying the same

standard as the trial court. Grafton v. Ohio Edison Co., 77 Ohio St.3d 102, 105

(1996). We give no deference to the trial court’s decision and independently review

the record to determine whether summary judgment is appropriate. Pursuant to

Civ.R. 56(C), the party seeking summary judgment must prove that (1) there is no

genuine issue of material fact; (2) they are entitled to judgment as a matter of law;

and (3) viewing the evidence in favor of the nonmoving party, reasonable minds can

come to but one conclusion and that conclusion is adverse to the nonmoving party.

See also Dresher v.

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2025 Ohio 5511, Counsel Stack Legal Research, https://law.counselstack.com/opinion/phillips-v-independence-ohioctapp-2025.