Rehm v. Eckinger

2024 Ohio 1860, 242 N.E.3d 222
CourtOhio Court of Appeals
DecidedMay 10, 2024
Docket2023CA00113
StatusPublished

This text of 2024 Ohio 1860 (Rehm v. Eckinger) 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
Rehm v. Eckinger, 2024 Ohio 1860, 242 N.E.3d 222 (Ohio Ct. App. 2024).

Opinion

[Cite as Rehm v. Eckinger, 2024-Ohio-1860.]

COURT OF APPEALS STARK COUNTY, OHIO FIFTH APPELLATE DISTRICT

LOUIS J. REHM, EXECUTOR OF THE : JUDGES: ESTATE OF JUNE A. REHM, : DECEASED : : : Hon. Patricia A. Delaney, P.J. Plaintiff-Appellant : Hon. W. Scott Gwin, J. : Hon. Craig R. Baldwin, J. -vs- : : Case No. 2023CA00113 : ROBERT W. ECKINGER, ET AL. : : : Defendants-Appellees : OPINION

CHARACTER OF PROCEEDING: Appeal from the Stark County Court of Common Pleas, Case No. 2022CV01486

JUDGMENT: REVERSED AND REMANDED

DATE OF JUDGMENT ENTRY: May 10, 2024

APPEARANCES:

For Plaintiff-Appellant: For Defendants-Appellees:

ADAM D. FULLER ANDREW J. DORMAN MONICA B. ANDRESS HOLLY MARIE WILSON 75 E. Market St. JESSICA S. FORREST Akron, OH 44308 200 Public Square, Suite 1200 Cleveland, OH 44114 [Cite as Rehm v. Eckinger, 2024-Ohio-1860.]

Delaney, P.J.

{¶1} Plaintiff-Appellant Louis J. Rehm, as Executor of the Estate of June A.

Rehm, Deceased, appeals the August 29, 2023 judgment entry of the Stark County Court

of Common Pleas.

FACTS AND PROCEDURAL HISTORY

Complaint for Legal Malpractice

{¶2} On September 13, 2022, Plaintiff-Appellant Loius J. Rehm, as Executor of

the Estate of June A. Rehm, Deceased, filed a complaint with the Stark County Court of

Common Pleas bringing a claim of legal malpractice against Defendants-Appellees

Robert W. Eckinger and Eckinger Law Offices, Ltd. In the complaint, Appellant alleged

that his mother, June A. Rehm, retained Appellees in June 2019 to prepare her estate

planning. One piece of her estate planning regarded her real property located in Orrville,

Ohio (“the Farm.”) On April 28, 2020, Appellant claimed that June Rehm told Appellees

to give Appellant (1) 75% interest in the Farm and (2) 100% of the mineral rights to the

Farm. She directed Appellees to give her other son, Carl Rehm Jr., a 25% interest in the

Farm.

{¶3} The Last Will and Testament of June A. Rehm, executed on May 13, 2020,

disposed of 75% interest in the Farm to Appellant, 25% interest in the Farm to Carl Rehm,

Jr., and 100% of the mineral rights in the Farm to Appellant (hereinafter, “2020 Will”). The

disposition was subject to the provision that Appellant had the option to purchase the

entire 25% interest of Carl Rehm, Jr. at the appraised fair market value or a value agreed

to by the parties. [Cite as Rehm v. Eckinger, 2024-Ohio-1860.]

{¶4} June Rehm died on August 30, 2021. Appellant retained Appellees to open

an estate for June Rehm.

{¶5} On October 17, 2021, Carl Rehm, Jr. filed an Affidavit pursuant to R.C.

5302.222, confirming a Transfer on Death Designation Affidavit that was recorded by the

Wayne County Recorder, Volume 889, Page 4642 on October 17, 2018. The Transfer on

Death Designation Affidavit (“TODDA”) recorded on October 17, 2018 was signed by

June A. Rehm and prepared by Attorney Melissa Craemer Smith. The TODDA stated that

upon the death of June Rehm, the entire undivided interest of the Farm would pass to

Appellant and Carl Rehm, Jr. as transfer on death beneficiaries with 50% of the Farm

going to Appellant and 50% of the Farm going to Carl Rehm, Jr.

{¶6} On October 14, 2021, Appellant claimed he became aware of the TODDA

through a realtor. On October 21, 2021, Appellees filed the application to probate the

2020 Will with the Wayne County Probate Court. The 2020 Will was admitted to probate

on November 4, 2021.

{¶7} The Farm was ultimately disposed of pursuant to the terms of the TODDA,

not the 2020 Will.

{¶8} Appellant filed his claim for legal malpractice against Appellees arguing that

they committed legal malpractice by failing to discover the existence of the TODDA and

failing to revoke the TODDA before preparing June Rehm’s estate plan.

Discovery

{¶9} On June 25, 2023, Appellees filed a Motion to Release Attorney-Client File. In

the motion, Appellees requested an order from the trial court permitting the release of the

attorney-client file of Attorney Melissa Craemer Smith and her law firm concerning the [Cite as Rehm v. Eckinger, 2024-Ohio-1860.]

representation of June Rehm and the preparation of the TODDA. Appellant as Executor

would not waive attorney-client privilege between Attorney Craemer Smith and the

deceased, June Rehm. Appellees asked the trial court to waive the attorney-client

privilege and confidentiality between Attorney Craemer Smith and June Rehm so that

Appellees could defend against Appellant’s legal malpractice claim. Appellees argued

that a key piece of its defense against Appellant’s claim of legal malpractice was that

June Rhem knew of the non-effect of the 2020 Will but wanted to sign it anyway.

Appellees argued that June Rehm’s intent was a key issue in the matter.

{¶10} In support of its motion, Appellees attached emails which it argued were

non-privileged communications received in discovery from Attorney Craemer Smith.

Exhibit B was an email from Attorney Craemer Smith dated August 4, 2022, which stated:

I don’t remember a specific incident, but I am sure this occurred when Louis

bullied his mother into removing [S.B.] (June’s friend) as her POA and she

changed her Will. I believe Louis and Amy were named as June’s new POA.

June is virtually blind, and she was very intimidated by Louis. I would expect

that June had no idea that she had established a joint account with Louis

and Amy.

(Exhibit B, Motion to Release Attorney-Client File, June 25, 2023). In a second email sent

from Attorney Craemer Smith on October 7, 2021, she stated:

Interesting. It looks like Louis may have convinced his mother to do a new

Will after all. Let me know when you get a copy of [the] Will, please. [Cite as Rehm v. Eckinger, 2024-Ohio-1860.]

(Exhibit C, Motion to Release Attorney-Client File, June 25, 2023). Appellees argued

these communications demonstrated Appellant’s involvement in the matter and

information from the attorney-client file would support their defense.

{¶11} Appellant responded to the motion, arguing the trial court did not have the

authority to compel disclosure of the file because Appellant had not waived the attorney-

client privilege and there was no recognized applicable exception to the privilege. Attorney

Craemer Smith also filed a motion to protect attorney-client communications and

documents, requesting the trial court quash Appellees’ subpoena. She argued there was

no exception in this case to the attorney-client privilege.

{¶12} In their reply to their motion, Appellees argued that Appellant was refusing

to waive the attorney-client privilege because the information would be harmful to

Appellant. Appellees argued that the discovery obtained so far in Appellant’s deposition,

the deposition of Carl Rehm, Jr., and Attorney Craemer Smith’s emails, it appeared that

Appellant pressured June Rehm as to the disposition of the Farm, resulting in the 2020

Will. The TODDA reflected June Rehm’s true intent in the disposition of the Farm.

Appellees raised the common law self-protection exception to the attorney-client privilege

as a basis for the trial court to grant its motion for the release of the attorney-client file.

{¶13} Appellant moved to strike Appellee’s reply for raising new issues not

argued in their original motion, or in the alternative, leave to file a sur-reply.

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Bluebook (online)
2024 Ohio 1860, 242 N.E.3d 222, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rehm-v-eckinger-ohioctapp-2024.