Riley v. Kavanaugh

2024 Ohio 5765
CourtOhio Court of Appeals
DecidedDecember 9, 2024
Docket2024-A-0059
StatusPublished
Cited by1 cases

This text of 2024 Ohio 5765 (Riley v. Kavanaugh) 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
Riley v. Kavanaugh, 2024 Ohio 5765 (Ohio Ct. App. 2024).

Opinion

[Cite as Riley v. Kavanaugh, 2024-Ohio-5765.]

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

JOSEPH RILEY, CASE NO. 2024-A-0059

Plaintiff-Appellee, Civil Appeal from the - vs - County Court, Western District

JULIE KAVANAUGH, Trial Court No. 2024 CVI 00139 W Defendant-Appellant.

OPINION

Decided: December 9, 2024 Judgment: Affirmed

Joseph Riley, pro se, 36250 Reeves Road, Eastlake, OH 44095 (Plaintiff-Appellee).

Julie Kavanaugh, pro se, 4244 State Route 534, Hartsgrove, OH 44085 (Defendant- Appellant).

JOHN J. EKLUND, J.

{¶1} Appellant, Julie Kavanaugh, appeals the judgment of the Ashtabula County

Court, Western Division, in favor of Appellee, Joseph Riley, after a small claims court

bench trial. The trial court found that Appellee had loaned Appellant $6,000.00.

Appellant’s brief asserts two assignments of error relating to the manifest weight and

sufficiency of the evidence.

{¶2} Having reviewed the record and the applicable caselaw, the trial court’s

judgment was not against the sufficiency of the evidence based on Appellee’s failure to

establish how Appellant used the money she received. Next, the trial court was in the best position to observe the witnesses and weigh their credibility. The court’s judgment was

not against the manifest weight of the evidence.

{¶3} Therefore, the judgment of the Ashtabula County Court, Western Division,

is affirmed.

Substantive and Procedural History

{¶4} On March 15, 2024, Appellee filed a pro se small claims complaint in the

Ashtabula County Court, Western Division. He claimed that “Julie Kavanaugh had

borrowed six thousand dollars from me over two years ago and has refused to pay me

back or even discuss the matter with me.”

{¶5} On April 23, 2024, the parties engaged in a mediation session and failed to

reach an agreement.

{¶6} On May 13, 2024, the trial court held a bench trial. Both parties appeared

pro se. At the hearing, Appellee stated that he had lent $6,000.00 to Appellant. Appellee

provided checks and bank statements demonstrating he gave Appellant a $5,000.00

check on March 15, 2021, and $1,000.00 check on July 20, 2021. Appellee stated the

money was given to Appellant as a loan. One of the checks had the words “I love you –

loan” written on the memo line. The trial court said that the word “loan” appeared to have

been written after the fact and asked Appellee if he wrote that. He denied writing the word

“loan” and said that Appellant wrote it on the check.

{¶7} Appellee testified that he and Appellant were engaged at the time he gave

her the checks. First, Appellant testified that the $1,000.00 check was a loan for Appellant

“that she borrowed for the bed” and “borrowed for posts and electric fence.” He said the

$5,000.00 loan was “to pay the barn she had put in by Eli Miller.” When asked follow-up

Case No. 2024-A-0059 questions about whether the money was intended as a gift or a loan, Appellee said that

the two were looking at houses together. He said that Appellant bought 15 acres of land

solely in her name, but to avoid a problem at the time of closing, she needed a loan to

complete the transaction, and he offered Appellant a loan to help.

{¶8} Appellant acknowledged receiving the money from Appellee but said that it

was a gift. She said that Appellee was a jilted lover and gave her the money to try to buy

her affection in a failing relationship. She denied needing the money or Appellee’s help

to secure financing or close the property sale. She acknowledged that five banks turned

her down “because I’m a nurse and sometimes we go to different facilities.” Despite this,

she said “I did it on my own.”

{¶9} The trial court ruled in favor of Appellee and granted judgment against

Appellant in the amount of $6,000.00 with interest thereon at the rate of 5% per annum.

{¶10} Appellant timely filed this pro se appeal and has raised two assignments of

error. Appellee has not filed an answer brief.

Assignments of Error and Analysis

{¶11} Appellant’s first assignment of error states: “The court committed prejudicial

error in awarding Plaintiff-Appellee Joseph Riley judgment against Defendant-Appellant

Julie Kavanaugh for the sum of $6,000.00, together with interest rate of 5% per annum

on the 13th day of May, 2024 with costs herein. When no documentation was provided of

alleged items purchased by Ms. Kavanaugh to substantiate Mr. Riley’s sworn testimony

in the courtroom.”

{¶12} Appellant’s second assignment of error states: “With respect to page 14-15

of the original transcripts submitted a review shows that in fact no loan was ever

Case No. 2024-A-0059 established between Mr. Riley and Ms. Kavanaugh. At that time the court had the

opportunity to request a promissory note with stipulations of repayment conditions for

clarification of the small claim before the court.”

{¶13} Appellant has filed this brief pro se. While a court may grant a pro se litigant

a certain degree of latitude, a “‘court cannot simply disregard the rules in order to

accommodate a party who fails to obtain counsel.’” Henderson v. Henderson, 2013-Ohio-

2820, ¶ 22 (11th Dist.), quoting Goodrich v. Ohio Unemp. Comp. Rev. Comm., 2012-

Ohio-467, ¶ 25 (10th Dist.). “[A] pro se litigant is held to the same standard as other

litigants and is not entitled to special treatment from the court.” Metzenbaum v. Gates,

2004-Ohio-2924, ¶ 7 (11th Dist.). Appellant’s appeal will be held to the same standard as

other litigants.

{¶14} App.R. 16(A) requires that the brief of the Appellant include, among other

things, “[a]n argument containing the contentions of the appellant with respect to each

assignment of error presented for review and the reasons in support of the contentions,

with citations to the authorities, statutes, and parts of the record on which appellant relies.

The argument may be preceded by a summary.” App.R. 16(A)(7).

{¶15} App.R. 12(A)(2) provides that “[t]he court may disregard an assignment of

error presented for review if the party raising it fails to identify in the record the error on

which the assignment of error is based or fails to argue the assignment separately in the

brief, as required under App.R. 16(A).”

{¶16} Accordingly, this court may disregard an assignment of error that fails to

comply with App.R. 12(A) or App.R. 16(A)(7). South Russell v. Upchurch, 2003-Ohio-

2099, ¶ 9 (11th Dist.).

Case No. 2024-A-0059 {¶17} Appellant’s brief contains two assignments of error; however, her brief does

not contain any argument in support of her assignments. To the extent we can discern,

Appellant’s assignments of error relate to the weight and sufficiency of the evidence

produced at trial.

{¶18} Appellant’s first assignment of error appears to challenge the trial court’s

judgment because “no documentation was provided of alleged items purchased” with the

money Appellee claims he loaned to Appellant. This is effectively a challenge to the

{¶19} Appellant’s second assignment of error appears to argue that the transcript

demonstrates that no loan was established, in contradiction to the trial court’s factual

finding that a loan was established. This is effectively a challenge to the manifest weight

of the evidence.

{¶20} “[O]n appeal from a bench trial we review the trial court’s factual findings

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Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 5765, Counsel Stack Legal Research, https://law.counselstack.com/opinion/riley-v-kavanaugh-ohioctapp-2024.