Selective Ins. Co. of Am. v. Bronco Excavating, Inc.

2022 Ohio 3805
CourtOhio Court of Appeals
DecidedOctober 26, 2022
DocketC-220163
StatusPublished
Cited by1 cases

This text of 2022 Ohio 3805 (Selective Ins. Co. of Am. v. Bronco Excavating, Inc.) 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
Selective Ins. Co. of Am. v. Bronco Excavating, Inc., 2022 Ohio 3805 (Ohio Ct. App. 2022).

Opinion

[Cite as Selective Ins. Co. of Am. v. Bronco Excavating, Inc., 2022-Ohio-3805.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

SELECTIVE INSURANCE CO. OF : APPEAL NO. C-220163 AMERICA, TRIAL NO. 21CV-18047 : Plaintiff-Appellant, : vs. O P I N I O N. : BRONCO EXCAVATING, INC.,

Defendant-Appellee. :

Civil Appeal From: Hamilton County Municipal Court

Judgment Appealed From Is: Reversed and Cause Remanded

Date of Judgment Entry on Appeal: October 26. 2022

Kreiner & Peters Co., LPA, and Daniel Kiefer, for Plaintiff-Appellant,

Bonezzi Switzer Polito & Hupp Co., LPA, Patricia J. Trombetta and Thomas J. Glassman, for Defendant-Appellee. OHIO FIRST DISTRICT COURT OF APPEALS

WINKLER, Judge.

{¶1} In this subrogation action, plaintiff-appellant Selective Insurance Co. of

America (“Selective Insurance”) appeals the decision of the trial court granting a Civ.R.

60(B) motion filed by defendant-appellee Bronco Excavating Inc. (“Bronco”). Because

Bronco failed to set forth any evidence of excusable neglect, we reverse the judgment

of the trial court.

Background

{¶2} On September 21, 2021, Selective Insurance filed a subrogation action

on behalf of its insured against Bronco arising from an incident in which one of

Bronco’s employees allegedly backed a dump truck into the insured’s parked vehicle.

Selective Insurance allegedly paid its insured $4,633.45 for the property damage, and

the insured paid $500 as an out-of-pocket deductible.

{¶3} On October 26, 2021, Selective Insurance filed a motion for a default

judgment, which the trial court granted on November 1, 2021. On November 4, 2021,

Bronco filed a motion to set aside the default judgment in accordance with Civ.R.

60(B). Bronco alleged that it had sent notice of the lawsuit to its insurance carrier via

email; however, the insurance carrier never received notice of the lawsuit.

{¶4} In March 2022, the trial court held a hearing on Bronco’s motion to set

aside the default judgment. Bronco did not present any evidence, and Bronco’s

attorney represented to the court that she did not have the email that her client had

sent to the insurance company notifying it of the lawsuit. Bronco’s attorney argued

that Selective Insurance’s insured had parked in a no-parking zone at the time of the

accident, and that the matter should have been arbitrated under an agreement

between Selective Insurance and Bronco’s insurer.

2 OHIO FIRST DISTRICT COURT OF APPEALS

{¶5} The trial court granted Bronco’s Civ.R. 60(B) motion, finding that

service of the motion for a default judgment had not been received by defendant until

after the default judgment had been entered, and that Bronco had a potential

meritorious defense.

{¶6} Selective Insurance appeals, raising three assignments of error.

Civ.R. 60(B) and Excusable Neglect

{¶7} In its first assignment of error, Selective Insurance argues that the trial

court abused its discretion in granting Bronco’s Civ.R. 60(B) motion without making

a finding of excusable neglect and where no evidence in the record supports excusable

neglect. To prevail under Civ.R. 60(B), a movant must establish: (1) a meritorious

defense or claim in the action; (2) entitlement to relief under one of the grounds set

forth in Civ.R. 60(B)(1) through (5); and (3) the movant’s motion was made within a

reasonable time, or within one year if the grounds for relief are Civ.R. 60(B)(1), (2), or

(3). GTE Automatic Elec., Inc. v. ARC Industries, Inc., 47 Ohio St.2d 146, 351 N.E.2d

113 (1976), paragraph two of the syllabus. An appellate court reviews a decision

granting or denying relief under Civ.R. 60(B) for an abuse of discretion. Griffey v.

Rajan, 33 Ohio St.3d 75, 77, 514 N.E.2d 1122 (1987). In general, an abuse of discretion

occurs where a trial court’s decision is “unreasonable, arbitrary or unconscionable.”

Blakemore v. Blakemore, 5 Ohio St.3d 217, 219, 450 N.E.2d 1140 (1983).

{¶8} Selective Insurance challenges the second prong of the GTE test—

whether Bronco was entitled to relief under Civ.R. 60(B)(1), which provides: “On

motion and upon such terms as are just, the court may relieve a party or his legal

representative from a final judgment, order or proceeding for * * * mistake,

inadvertence, surprise or excusable neglect[.]”

3 OHIO FIRST DISTRICT COURT OF APPEALS

{¶9} Bronco argued in the trial court that it had forwarded a copy of the

complaint to its insurance carrier via email, but the insurance carrier never received

it. However, Bronco failed to provide any evidence or details to support its assertion

regarding the email. According to Selective Insurance, Bronco’s conduct is not

excusable neglect, and Selective Insurance relies on two cases from this court: Scheper

v. McKinnon, 177 Ohio App.3d 820, 2008-Ohio-3964, 896 N.E.2d 208 (1st Dist.), and

Mueller v. Hammann, 1st Dist. Hamilton Nos. C-120799 and C-130231, 2013-Ohio-

5098.

{¶10} In Scheper, this court held that a trial court did not abuse its discretion

in denying a defendant’s Civ.R. 60(B) motion where the defendant-insured forwarded

a complaint to its insurance company, but neither the defendant nor the insurer took

any further action until almost five months after the judgment had been entered for

the plaintiffs. Similarly, in Mueller, this court held that the trial court did not abuse

its discretion in denying a Civ.R. 60(B) motion filed by a defendant who had allegedly

retained an attorney, but neither the defendant nor the attorney took any further

action to respond or defend.

{¶11} Bronco argues that this court should uphold the trial court’s decision to

set aside the default judgment, and Bronco relies on Colley v. Bazell, 64 Ohio St.2d

243, 416 N.E.2d 605 (1985). In Colley, the defendant-attorney promptly mailed a copy

of a malpractice complaint to his insurance agent by certified mail; however, the

paperwork became delayed in the mail and did not arrive until the same day that the

trial court granted the plaintiffs’ default-judgment motion. The trial court denied the

defendant-attorney’s motion to set aside the default judgment and reasoned that the

4 OHIO FIRST DISTRICT COURT OF APPEALS

defendant should have followed through with his insurance company to make sure

that it would respond to the lawsuit on his behalf.

{¶12} The Ohio Supreme Court reversed the trial court’s decision in Colley.

The court reasoned that whether neglect is excusable necessitates an inquiry into all

of the facts and circumstances, including “whether the defendant promptly notified

his carrier of the litigation[;] * * * the lapse of time between the last day for the filing

of a timely answer and the granting of the default judgment[;] * * * the amount of the

judgment granted[; and] * * * the experience and understanding of the defendant with

respect to litigation matters.” Colley at 248-249. The Colley court reasoned that the

trial court focused on defendant’s status as an attorney, but the trial court ignored the

defendant’s prompt notice to the insurance carrier, the substantial amount of the

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