PNC Bank Natl. Assn. v. Whitaker

2025 Ohio 1078
CourtOhio Court of Appeals
DecidedMarch 27, 2025
Docket2024 CA 00021
StatusPublished
Cited by2 cases

This text of 2025 Ohio 1078 (PNC Bank Natl. Assn. v. Whitaker) 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
PNC Bank Natl. Assn. v. Whitaker, 2025 Ohio 1078 (Ohio Ct. App. 2025).

Opinion

[Cite as PNC Bank Natl. Assn. v. Whitaker, 2025-Ohio-1078.]

COURT OF APPEALS FAIRFIELD COUNTY, OHIO FIFTH APPELLATE DISTRICT

PNC BANK NATIONAL : JUDGES: ASSOCIATION SUCCESSOR : Hon. Craig R. Baldwin, P.J. BY MERGER : Hon. Michael D. Hess, J. : Hon. Jason P. Smith, J. Plaintiff-Appellee : : -vs- : Judges Hess and Smith : Sitting by Assignment by the : Supreme Court of Ohio : JEFF WHITAKER, ET AL. : Case No. 2024 CA 00021 : Defendants-Appellants : OPINION

CHARACTER OF PROCEEDINGS: Appeal from the Fairfield County Court of Common Pleas, Case No. 2019 CV 00235

JUDGMENT: Affirmed

DATE OF JUDGMENT ENTRY: March 27, 2025

APPEARANCES:

For Plaintiff-Appellee For Defendant-Appellant

H. TOBY SCHISLER MARIAN D. DAVIDSON Dinsmore & Shohl, LLP 120 McKinley Street 225 East Fifth Street, Suite 1900 Lisbon, Ohio 44432 Cincinnati, Ohio 45202 Hess, J.

{¶1} Defendant-Appellant Jeff Whitaker appeals the trial court’s order granting

summary judgment in favor of plaintiff-appellee PNC Bank National Association (PNC

Bank) on its foreclosure action and against Whitaker on his counterclaims.

I. FACTS AND PROCEDURAL HISTORY

{¶2} Whitaker executed a promissory note on April 25, 2005 payable to PNC

Bank’s predecessor-in-interest, National City Mortgage, in the original principal amount

of $103,600.00, plus interest. The note was secured by an open-end mortgage executed

by Whitaker pledging real property located at 201 North Liberty Street, Baltimore, Ohio

as collateral and recorded in Fairfield County, Ohio as Instrument Number

200500010511. National City Mortgage merged with PNC Bank and the note was

endorsed in blank. Upon the merger, PNC Bank acquired the note and mortgage.

{¶3} On October 19, 2015, PNC Bank mailed Whitaker a notice of default and

acceleration letter. PNC Bank initiated a foreclosure action against Whitaker in 2015. This

prior foreclosure action was dismissed pursuant to a 2018 settlement agreement, which

included a trial modification under which Whitaker was to make three monthly payments

in a reduced amount. If Whitaker timely made the three payments, the parties would enter

into a permanent modification. Whitaker made the timely payments and PNC Bank mailed

Whitaker the permanent modification agreement. Whitaker never signed or returned the

permanent modification agreement. As a result, PNC Bank sent Whitaker a letter in

January 2019 advising him that the original terms of the note and mortgage applied, and

any prior foreclosure activity would resume. In April 2019, PNC Bank filed this foreclosure

action. {¶4} The foreclosure action was stayed for over two years while the parties

pursued mediation. During mediation, the parties attempted a second unsuccessful

modification. The action was placed back on the active docket and PNC Bank filed a

motion for summary judgment supported by the affidavit of William Hardrick, an officer of

PNC Bank. Whitaker opposed the motion with his own affidavit and the affidavit of his

attorney, Marian Davidson, who represented Whitaker in both the prior and the current

foreclosure actions. PNC Bank filed a reply. Whitaker also filed a motion to strike the

October 19, 2015 notice of default and acceleration letter (“default letter”) that was

attached as exhibit 4 to PNC Bank’s summary judgment motion and authenticated by the

Hardrick affidavit. PNC Bank opposed the motion to strike and Whitaker filed a reply.

{¶5} The trial court denied Whitaker’s motion to strike the default letter and

granted PNC Bank’s motion for summary judgment on its foreclosure action and against

Whitaker’s counterclaims. Whitaker appealed.

II. ASSIGNMENTS OF ERROR

{¶6} Whitaker identified two assignments of error for review:

I. The Trial Court erred and abused its discretion by denying Appellant’s Motion to Strike Exhibit 4 of the Affidavit of William Hardrick (Appellee’s alleged October 19, 2015 Notice of Default) despite Appellee’s failure to properly authenticate said Exhibit, as well as to establish its applicability to the instant action due to the preexisting Dismissal of a previous foreclosure case that said Exhibit pertained exclusively to.

II. The Trial Court erred and abused its discretion by granting Appellee’s Motion for Summary Judgment on its claims, as well as on Appellant’s Counterclaims despite genuine issues of material fact relating thereto.

III. LEGAL ANALYSIS

A. Motion to Strike Default Letter {¶7} “The decision whether to grant or deny a motion to strike is governed by the

abuse of discretion standard of review.” Mackey v. Altercare of Hartville Ctr. for Rehab. &

Nursing Care, 2023-Ohio-1581, ¶ 41 (5th Dist.). “Abuse of discretion is more than an error

of law or judgment; rather, it implies that the court's attitude is unreasonable, arbitrary, or

unconscionable.” Id. at ¶ 21, citing Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983).

{¶8} PNC Bank supported its motion for summary judgment with the October 19,

2015 default letter attached as exhibit 4 to Hardrick’s affidavit. In his affidavit, Hardrick

stated that he was a PNC Bank officer and that his statements were based on personal

knowledge. He testified that PNC Bank maintained, as part of its regular business

practices and record keeping system, a computer database of communications for the

mortgage loans it services. These communications are made in the ordinary course of

business and Hardrick testified that he had access to those business records and that his

statements about them were made based on personal knowledge. Hardrick authenticated

the note and the mortgage and testified that the note was in default for the payment due

October 1, 2015. Hardrick testified that the October 19, 2015 default letter was mailed to

Whitaker and that a true and accurate copy of the default letter was attached to his

affidavit as exhibit 4.

{¶9} Whitaker challenged the authenticity of the default letter and argued that it

was “a sham” because it referenced a “06-08-15” date in the extreme bottom right side of

the letter that was more than four months prior to the October 19, 2015 date of the letter.

Whitaker also argued that the letter was not a true and accurate copy of the original, but

was labeled as an “internet reprint,” that it reflected an inaccurate overdue amount, and

that it did not specify the action required to cure the default. Whitaker also contended that a prior default letter sent in May 2011 was found to be deficient by a court in a prior

foreclosure proceeding.

{¶10} PNC Bank opposed the motion to strike, arguing that Whitaker’s challenges

went to the weight to be given to the default letter, not its admissibility, and were not

appropriate grounds for a motion to strike. PNC Bank argued that Hardrick’s affidavit

complied with the requirements of Civ.R. 56(E) governing affidavits in support of summary

judgment motions and that his affidavit fully established the appropriate evidentiary

foundation for the default letter. PNC Bank then addressed Whitaker’s main contention

with the default letter – that the date “06-08-15” in the lower right-hand corner was not the

same as the “October 19, 2015” date on letter. PNC Bank submitted a second affidavit

from Hardrick in which he explained that the reference to “06-08-15” on the bottom right

side reflected that the template used for the notice was most recently updated on June 8,

2015.

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Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 1078, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pnc-bank-natl-assn-v-whitaker-ohioctapp-2025.