Stealey v. Belpre City School Dist.

2025 Ohio 4899
CourtOhio Court of Appeals
DecidedOctober 17, 2025
Docket25CA18
StatusPublished

This text of 2025 Ohio 4899 (Stealey v. Belpre City School Dist.) 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
Stealey v. Belpre City School Dist., 2025 Ohio 4899 (Ohio Ct. App. 2025).

Opinion

[Cite as Stealey v. Belpre City School Dist., 2025-Ohio-4899.]

IN THE COURT OF APPEALS OF OHIO FOURTH APPELLATE DISTRICT WASHINGTON COUNTY

BARBARA STEALEY, : : Plaintiff-Appellant, : Case No. 25CA18 : v. : : BELPRE CITY SCHOOL DISTRICT, : DECISION AND JUDGMENT : ENTRY Defendant-Appellee. : : RELEASED 10/17/2025 _____________________________________________________________ APPEARANCES:

Ethan Vessels, Fields, Dehmlow & Vessels, LLC, Marietta, Ohio for Plaintiff- Appellant.

Thomas N. Spyker and Michael J. Valentine, Reminger Co., LPA, Columbus, Ohio for Defendant- Appellee.

Hess, J.

{¶1} Barbara Stealey appeals the judgment of the Washington County

Court of Common Pleas granting summary judgment in favor of Belpre City School

District (“School”) on her negligence claim for injuries she sustained when she

tripped on a mat in the gymnasium while attending a funeral service. Stealey

contends that the trial court erred in granting summary judgment to the School

because: (1) the School was not immune from liability because a School

employee’s negligence caused her injuries; (2) the hazard was not open and

obvious because she was not required to be constantly looking down for hazards;

and (3) she was a social guest, not a licensee, and therefore the School had a duty

to exercise ordinary care and there was a genuine issue of material fact concerning

whether the School exercised such care. Washington App. No. 25CA18 2

{¶2} The School argues that it is a political subdivision and is immune

from liability because Stealey has failed to allege or present evidence that there

was a physical defect within or on the grounds of the gymnasium. And, even if the

mats constituted a physical defect, Stealey has no evidence that the use of the

mats was done with malicious purpose, bad faith, or in a wanton or reckless

manner. Thus, the School argues that the trial court’s finding that it is entitled to

immunity is correct and should be affirmed. The School also asserts that Stealey

relies on inapplicable case law and inadmissible evidence to impose a heightened

standard of care and that she can point to no facts that negate the open and

obvious nature of the hazard. Finally, the School asserts that the trial court properly

characterized Stealey as a licensee because she was there to attend a funeral,

which conferred no personal benefit upon the School.

{¶3} We find that the trial court properly granted summary judgment in

favor of the School on its political immunity defense. Stealey presented no

evidence that a physical defect existed in the gymnasium mats, either inherently

or due to the nature in which they were set up. We overrule her sole assignment

of error and affirm the trial court’s judgment.

I. FACTS AND PROCEDURAL BACKGROUND

{¶4} In February 2023, the School hosted a funeral service in the

gymnasium. The School staff set up the gymnasium by cleaning it, setting up

chairs and bleachers, and placing protective mats on the floor. Stealey attended

the funeral. She entered the lobby and proceeded to the gymnasium, stepping

directly onto the mats as she walked into the gymnasium and down the aisle to a Washington App. No. 25CA18 3

row of chairs. As she walked down the row, Stealey caught her foot on a mat, fell

forward, and broke her arm. She was 89 years old at the time of the fall.

{¶5} After Stealey filed her lawsuit, she began to suffer from dementia,

could not remember the fall, and was incompetent to testify. Thus, the account of

her fall comes from video footage from the School’s cameras.1 Stealey had fallen

three times prior to the funeral, but was not injured. She had fallen three times in

the 12 months following the funeral, suffering a broken hip and a broken pelvis in

two of the falls. Stealey had also suffered a possible mini-stroke prior to the funeral

in January 2023 and her physician suspended her driving privileges for six weeks.

She had just regained them the day before the funeral.

{¶6} Scott Trew, the facilities and transportation director of the School at

the time of the funeral, gave deposition testimony about the mats. He testified that

the protective mats were made of very thick vinyl material and were placed down

over the entire floor and were flattened. The mats were very large and were used

to cover the entire gymnasium floor. The staff would lay out the mats, flatten them,

and place chairs on top. The School had used the same mats repeatedly for events

such as graduations, dances, and assemblies for many years without incident.

School staff would place the mats down and ensure they laid flat but did not tape

the mats to the gymnasium floor.

{¶7} The video from the School’s cameras showed that Stealey and a

companion entered the lobby and proceeded to the gymnasium entrance. Stealey

1 Stealey’s daughter provided deposition testimony about Stealey’s fall history, injuries, medical

care, and dementia. The deposition was filed by the School in support of its summary judgment motion. Washington App. No. 25CA18 4

held the hand of her companion as she walked through the lobby and over two

black lobby floor mats. Video from the interior of the gymnasium shows Stealey

and her companion enter the gymnasium. The floor of the gymnasium was covered

entirely by large vinyl matting distinctly different from the wood gymnasium flooring,

and which laid flat and flush with the floor. Stealey and her companion walked

across the floor mats and traversed approximately two-thirds of the gymnasium

floor atop the matting without incident. Stealey continued to hold her companion’s

hand as she walked across the gymnasium mats. The two approached an aisle of

chairs and turned to enter the aisle. At this point, Stealey had released her

companion’s hand, stepped forward, and tripped over a flattened section of a mat

– the mat’s edge was not raised, buckled, curled, gaping, or otherwise elevated,

but was laying flush with the floor. As Stealey moved forward into the row, her right

foot wedged underneath the mat and she fell forward, lifting the mat’s edge with

her forward motion.

{¶8} The School filed a motion for summary judgment in which it argued

that it was entitled to immunity because Stealey did not establish a physical defect.

Stealey did not allege that the mats were in a defective condition but instead

claimed that the mats should have been taped to the floor. The School argued in

the alternative, that even if the mats were defective, the School’s immunity was

reinstated because she had no evidence that the School acted “with malicious

purpose, in bad faith, or in a wanton or reckless manner.”

{¶9} The School also argued that even if it were not immune from tort

liability, Stealey’s negligence claim fails as a matter of law because any danger Washington App. No. 25CA18 5

associated with the mats was open and obvious. And, because Stealey was a

licensee, the only duty the School owed her was to refrain from wantonly or willfully

causing injury and there was no evidence that the School acted wantonly or willfully

in its duty towards Stealey.

{¶10} Stealey opposed the motion. Stealey argued that the School’s failure

to tape down the mats’ edges created a trip hazard, was negligent, and caused

her injuries. She also argued the mats were not open and obvious and that she

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2025 Ohio 4899, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stealey-v-belpre-city-school-dist-ohioctapp-2025.