RBT Strategies v. Hungington Bancshares

2025 Ohio 145
CourtOhio Court of Appeals
DecidedJanuary 21, 2025
Docket2024-L-038
StatusPublished

This text of 2025 Ohio 145 (RBT Strategies v. Hungington Bancshares) 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
RBT Strategies v. Hungington Bancshares, 2025 Ohio 145 (Ohio Ct. App. 2025).

Opinion

[Cite as RBT Strategies v. Hungington Bancshares, 2025-Ohio-145.]

IN THE COURT OF APPEALS OF OHIO ELEVENTH APPELLATE DISTRICT LAKE COUNTY

RBT STRATEGIES, LLC, et al., CASE NO. 2024-L-038

Plaintiffs-Appellants, Civil Appeal from the - vs - Court of Common Pleas

HUNTINGTON BANCSHARES INCORPORATED d.b.a. THE Trial Court No. 2023 CV 001706 HUNTINGTON NATIONAL BANK, et al.,

Defendant-Appellee.

OPINION

Decided: January 21, 2025 Judgment: Affirmed

Evan T. Byron, Kaufman, Drozdowski & Grendell, LLC, 29525 Chagrin Boulevard, Suite 250, Pepper Pike, OH 44122 (For Plaintiffs-Appellants).

Christopher J. Niekamp, Erin L. Dickinson, David Robinson, and Jacob A. Kelly, Buckingham, Doolittle & Burroughs, LLC, 3800 Embassy Parkway, Suite 300, Akron, OH 44333 (For Defendant-Appellee).

MARY JANE TRAPP, J.

{¶1} This case arises from a bankruptcy adversary proceeding in which

appellants purchased claims from the bankruptcy trustee in exchange for $150,000.

Appellants, RBT Strategies, LLC, Equitable Strategies, LLC, and Thomas Muniak

(collectively, “RBT Strategies”), then filed the same federal- and state-law based claims

in the trial court below. RBT Strategies appeals the judgment entry of the Lake County

Court of Common Pleas that granted a motion to dismiss filed by appellee, Huntington

Bancshares Incorporated d/b/a The Huntington National Bank (“Huntington”). {¶2} RBT Strategies raises one assignment of error on appeal, contending the

trial court erroneously granted Huntington’s motion to dismiss because the statute of

limitations has not run on its state law claim and because the trial court has subject matter

jurisdiction over its assigned claims from the bankruptcy estate.

{¶3} After a careful review of the record and pertinent law, we find RBT

Strategies’ assignment of error to be without merit. The applicable statute of limitations

on its state-law fraudulent-transfer claims was four years, which allegedly occurred in

April 2019. The assigned claims were dismissed from the adversary proceeding in

December 2022, giving RBT Strategies four months to file its state law claims in state

court. However, it did not do so and waited until December 2023 to file its complaint in

the instant case. Further, we agree with the trial court that the portion of RBT Strategies’

assigned claims asserted on behalf of the bankruptcy estate and under federal

bankruptcy law should be asserted in the federal bankruptcy case. It belies common

sense that a trustee’s statutory powers to bring state law claims in a federal bankruptcy

case would be pleaded in a complaint filed in state court.

{¶4} The judgment of the Lake County Court of Common Pleas is affirmed.

Substantive and Procedural History

{¶5} In December 2023, RBT Strategies filed a complaint in the Lake County

Court of Common Pleas, as assignees of the U.S. Chapter 7 bankruptcy trustee in In re:

Prestige Worldwide Furniture, LLC, N.D. Ohio Bankr. No. 19-15022-aih, of claims in the

trustee’s adversary case, Robert D. Barr, Trustee in Bankruptcy v. Equitable Strategies,

LLC, N.D. Ohio Bankr.Adv. Proc. No. 21-01045-aih (“Barr v. Equitable Strategies”). RBT

Case No. 2024-L-038 Strategies brought its complaint against Huntington and National Strategic Corporation

LLC.1

{¶6} RBT Strategies alleged that in August 2019, Prestige Worldwide Furniture,

LLC (“PWF”) filed for Chapter 11 bankruptcy in the Northern District of Ohio Bankruptcy

Court. In December 2019, the case was converted to a Chapter 7 bankruptcy. In August

2021, the trustee filed the adversary proceeding, Barr v. Equitable Strategies, against

RBT Strategies, Equitable Strategies, and Mr. Muniak (the appellants in this

case/collectively “RBT Strategies”); Huntington and National Strategic Corporation LLC

(“the Other Defendants”); and three other entities, RS Consultants LLC, Volley Source

LLC, and BMT Endeavors LLC.

{¶7} In September 2022, the bankruptcy court accepted a settlement agreement

between the trustee and RBT Strategies in which RBT Strategies agreed to pay $150,000

in exchange for an assignment of the trustee’s claims against Huntington and National

Strategic Corporation LLC. Specifically, the trustee assigned “all of the Trustee’s rights,

interest, claims, etc. against the Other Defendants under 11 U.S.C. 544, 548, 550, and

551, and other applicable bankruptcy law and state law (i.e., R.C. 1313.56 and 1336.01

et. seq., including, without limitation, the [Other Defendant] Claims.” After receiving the

settlement payment, the trustee filed a notice of voluntary dismissal of his claims against

RBT Strategies, Huntington, and National Strategic Corporation LLC in December 2022.

{¶8} RBT Strategies further alleged that its assigned claims arose from a

$900,000 loan PWF obtained from Northwest Bank shortly before it filed for bankruptcy

1. RBT Strategies’ claims against National Strategic Corporation LLC are currently pending in the trial court. 3

Case No. 2024-L-038 in April 2019. In its count against Huntington, RBT Strategies alleged that in anticipation

of filing for bankruptcy, PWF fraudulently transferred or caused to be transferred

$436,650.77 to Huntington via three checks: (1) check no. 1025, in the amount of

$250,000, on April 2, 2019; (2) check no. 1027, in the amount of $46,650.77, on April 3,

2019; and (3) check no. 1028, in the amount of $140,000, on April 18, 2019. RBT

Strategies alleged that PWF received nothing in exchange for the transfers, the transfers

were made to defraud creditors, the transfers were made to prefer Huntington over PWF’s

other creditors, and the transfers were fraudulent.

{¶9} RBT Strategies prayed for the transfers to either be avoided and preserved

as fraudulent transfers pursuant to 11 U.S.C. 544, 548, 550, and 551 or for a monetary

judgment against HNB for the sum of $436,650.77.

{¶10} Attached to RBT Strategies’ complaint were filings from the adversary

proceedings, including the trustee’s complaint, the trustee’s motion for authority to

compromise certain fraudulent claims with the proposed settlement agreement between

RBT Strategies and the trustee, a court notice on the trustee’s motion, the court’s order

authorizing the compromise of certain fraudulent claims and the settlement agreement,

and the trustee’s notice of voluntary dismissal of the claims against RBT Strategies,

Huntington, and National Strategic Corporation LLC.

Huntington’s Motion to Dismiss

{¶11} Huntington filed a Civ.R. 12(B)(1) and (6) motion to dismiss, contending

RBT Strategies’ assigned claims should dismissed for lack of subject matter jurisdiction

since the bankruptcy court has exclusive jurisdiction, and the statute of limitations has

Case No. 2024-L-038 passed for its individual state law claims. In addition, RBT Strategies failed to sufficiently

plead a necessary element of its R.C. 1313.56 claim.

{¶12} Huntington clarified that Mr. Muniak, named by the trustee in the adversary

proceeding, was the owner, operator, and member of RBT Strategies, Equitable

Strategies, LLC, and PWF. Thus, RBT Strategies had actual knowledge of the fraudulent

transfers when they occurred.

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2025 Ohio 145, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rbt-strategies-v-hungington-bancshares-ohioctapp-2025.