The Home Loan Savings Bank v. City of Coshocton

CourtDistrict Court, S.D. Ohio
DecidedJanuary 26, 2023
Docket2:21-cv-00133
StatusUnknown

This text of The Home Loan Savings Bank v. City of Coshocton (The Home Loan Savings Bank v. City of Coshocton) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The Home Loan Savings Bank v. City of Coshocton, (S.D. Ohio 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

The Home Loan Savings Bank, Case No: 2:21-cv-133 Plaintiff, Judge Graham v. Magistrate Judge Jolson City of Coshocton, et al.,

Defendants.

Opinion and Order

Plaintiff Home Loan Savings Bank brings this action under 42 U.S.C. § 1983 against defendants City of Coshocton and the Coshocton City Utilities Department. Home Loan owns real property in Coshocton and alleges that defendants violated its right to due process when they, by operation of city ordinance, charged Home Loan with unpaid water bills incurred by the previous property owner. This matter is before the Court on defendants’ motion for summary judgment. As set forth below, the Court grants the motion as to Home Loan’s federal due process claim and declines to exercise supplemental jurisdiction over Home Loan’s state law claims. I. Background Home Loan provided loans, secured by mortgages, to a private citizen for the purchase of two parcels of real property in Coshocton, Ohio. Defendants supplied water services to both properties. The home owner fell behind on his mortgage payments and his water bills. He deeded the properties to Home Loan in lieu of foreclosure, and Home Loan recorded its interest in the properties. Following the transfers of title, defendants sent invoices to Home Loan demanding payment of the unpaid water charges incurred by the prior owner. They made the demand pursuant to City of Coshocton Codified Ordinances 933.04 and 933.08. Ordinance 933.04 provides that the “Owner shall be responsible for the payment of all water service charges regardless of the party or parties occupying, using or consuming water service at the Served Premises.” Ordinance 933.08 provides that “[a]ny conveyance of title shall be subject to any past due or then current but unpaid water, wastewater and sanitation charges and shall remain subject to the termination provisions contained in this Chapter 933.” Home Loan filed suit alleging that defendants violated Home Loan’s procedural due process rights under the Fourteenth Amendment of the United States Constitution because Home Loan was not given notice of defendants’ demand for payment of the unpaid water charges before taking title to the properties. Home Loan further seeks declaratory relief that the Ordinances violate the Ohio Constitution and certain provisions of Ohio law. II. Standard of Review Under Federal Rule of Civil Procedure 56, summary judgment is proper if the evidentiary materials in the record show that there is “no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a); see Longaberger Co. v. Kolt, 586 F.3d 459, 465 (6th Cir. 2009). The moving party bears the burden of proving the absence of genuine issues of material fact and its entitlement to judgment as a matter of law, which may be accomplished by demonstrating that the nonmoving party lacks evidence to support an essential element of its case on which it would bear the burden of proof at trial. See Celotex Corp. v. Catrett, 477 U.S. 317, 322-23 (1986); Walton v. Ford Motor Co., 424 F.3d 481, 485 (6th Cir. 2005). A district court considering a motion for summary judgment may not weigh evidence or make credibility determinations. Adams v. Metiva, 31 F.3d 375, 379 (6th Cir. 1994). Rather, in reviewing a motion for summary judgment, a court must determine whether “the evidence presents a sufficient disagreement to require submission to a jury or whether it is so one-sided that one party must prevail as a matter of law.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 251-52 (1986). The evidence, all facts, and any inferences that may permissibly be drawn from the facts must be viewed in the light most favorable to the nonmoving party. Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587 (1986); Eastman Kodak Co. v. Image Technical Servs., Inc., 504 U.S. 451, 456 (1992). III. Defendant Coshocton City Utilities Department correctly argues that Home Loan’s claims against it fail because the department is not sui juris and therefore lacks the capacity to be sued. Under Ohio Revised Code § 715.01, “Each municipal corporation is a body politic and corporate, which . . . [may] sue and be sued. . . .” However, there is no statutory authority affording a municipal department that same capacity. See Larson v. Canton City Utilities, 2019-Ohio-5400, ¶ 19 (Ohio Ct. App.) (“Canton City Utilities, as a department of the City of Canton, a municipal corporation, is not sui juris and cannot be sued absent statutory authority.”); Torrance v. Firstar, 529 F.Supp.2d 836, 850 (S.D. Ohio 2007) (“The Cincinnati Water Works, as a department of the City of Cincinnati, a municipal corporation, is not sui juris.”). To the extent that Home Loan’s claims concern the actions of the Coshocton City Utilities Department in demanding payment, Home Loan may proceed against the legally responsible entity, defendant City of Coshocton. IV. Due Process To establish a procedural due process claim in a § 1983 action, plaintiff must demonstrate the following three elements: (1) plaintiff has “a life, liberty, or property interest protected by the Due Process Clause of the Fourteenth Amendment,” (2) plaintiff was “deprived of this protected interest within the meaning of the Due Process Clause,” and (3) defendant did not afford plaintiff “adequate procedural rights” prior to the deprivation. Hahn v. Star Bank, 190 F.3d 708, 716 (6th Cir. 1999). For purposes of the pending motion for summary judgment, the Court assumes that the first two elements are satisfied.1 Home Loan argues that due process required that the City, prior to Home Loan taking title to the properties, provide Home Loan with notice and an opportunity to be heard on its demand for payment of the previous owner’s unpaid water charges. The City, which made the demand pursuant to Ordinances 933.04 and 933.08, argues that citizens do not have an individual right to be heard before they are affected by laws of general applicability. The Court finds that the City is correct. The controlling principle is found in Bi-Metallic Inv. Co. v. State Bd. of Equalization, 239 U.S. 441, 445 (1915). In Bi–Metallic, the United States Supreme Court held that due process did not require a hearing for each landowner affected by a generally- applicable law which increased the valuation of all taxable property in Denver, Colorado by 40%. “General statutes within the state power are passed that affect the person or property of individuals, sometimes to the point of ruin, without giving them a chance to be heard. Their rights are protected

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The Home Loan Savings Bank v. City of Coshocton, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-home-loan-savings-bank-v-city-of-coshocton-ohsd-2023.