Timmons v. Hull

2024 Ohio 178
CourtOhio Court of Appeals
DecidedJanuary 19, 2024
Docket2023-CA-23
StatusPublished

This text of 2024 Ohio 178 (Timmons v. Hull) 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
Timmons v. Hull, 2024 Ohio 178 (Ohio Ct. App. 2024).

Opinion

[Cite as Timmons v. Hull, 2024-Ohio-178.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT CLARK COUNTY

JAMES TIMMONS, ET AL. : : Appellees : C.A. No. 2023-CA-23 : v. : Trial Court Case No. 19-CV-0297 : JAMES HULL, ET AL. : (Civil Appeal from Common Pleas : Court) Appellants : :

...........

OPINION

Rendered on January 19, 2024

RYAN L. THOMAS, Attorney for Appellants

EDWARD A. FRIZZELL, Attorney for Appellees

.............

LEWIS, J.

{¶ 1} Defendants-Appellants James Hull and Tuara Hull (collectively “Defendants”)

appeal from a judgment of the Clark County Court of Common Pleas, which granted

summary judgment in favor of Plaintiffs-Appellees James Timmons and Larry Timmons

(collectively “Plaintiffs”) on their unjust enrichment claim and awarded damages. For the -2-

following reasons, we will reverse the judgment of the trial court and remand for further

proceedings.

I. Procedural History and Facts

{¶ 2} Plaintiffs, who are brothers, were equal partners in a farming business that

included buying and selling livestock. As part of that business, Plaintiffs sold cattle to

James Hull between approximately 2009 and 2017 based on a handshake agreement.

On June 10, 2019, Plaintiffs filed a civil action in the Clark County Court of Common Pleas

against the Defendants alleging breach of contract, unjust enrichment, and fraud relating

to the buying and selling of cattle during seven separate transactions that occurred over

the course of approximately one year.

{¶ 3} According to Plaintiffs, it was the practice of the parties for James Hull to

make payment for the cattle immediately upon delivery of the cattle to James Hull or within

30 days of delivery. James Hull was a middleman who purchased heifers from Plaintiffs

and resold the cows to other dairy farmers or at market. Around 2016, James Hull

purchased cattle from Plaintiffs on seven separate occasions in which he wrote checks

for each transaction but requested Plaintiffs not cash the checks due to having insufficient

funds. All the checks were written on a joint checking account in the name of James and

Tuara Hull, as husband and wife. Plaintiffs alleged that Defendants never made good

on the seven checks and therefore owed them $128,950, the aggregate amount of all the

checks. Although Plaintiffs attempted to collect the amount, Defendants denied that they

owed any payments to Plaintiffs and refused to pay, which led to the filing of the complaint.

{¶ 4} According to the Defendants’ answer to the complaint, James Hull admitted -3-

that he and Plaintiffs had engaged in the sale and purchase of cattle for several years.

However, Defendants denied that they owed Plaintiffs any money as all the transactions

had been paid in full, either by James Hull or a third party for the benefit of the Plaintiffs,

after evaluating the cattle.

{¶ 5} On February 26, 2021, Plaintiffs filed a motion for leave to file a motion for

summary judgment. Although the trial court sustained Plaintiffs’ motion for leave to file

a motion for summary judgment, additional discovery and depositions were completed

before Plaintiffs ultimately filed their motion.

{¶ 6} On November 12, 2021, Plaintiffs filed a motion for summary judgment as to

all claims. Following several joint continuances and additional discovery and

depositions, Defendants filed a response to the motion for summary judgment. In their

response, Defendants asserted that there was an issue of material fact in dispute and,

further, they requested that Tuara Hull be dismissed from the case as she had no

involvement in the purchasing and selling of any cattle.

{¶ 7} On February 4, 2022, the trial court granted Plaintiffs’ motion for summary

judgment solely on the claim of unjust enrichment against both James and Tuara Hull and

ordered a hearing to determine damages. Following a damages hearing and closing

arguments, the trial court issued a judgment that awarded damages to Plaintiffs in the

amount of $120,150.00. The remaining two claims for fraud and breach of contract were

voluntarily dismissed by Plaintiffs on April 21, 2023.

{¶ 8} Defendants filed a timely notice of appeal and raise the following two

assignments of error relating to the unjust enrichment claim: -4-

1. THE TRIAL COURT ERRED TO THE PREJUDICE OF DEFENDANTS

IN GRANTING PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT

FOR UNJUST ENRICHMENT BY WEIGHING THE EVIDENCE TO

RESOLVE QUESTIONS OF FACT IN FAVOR OF THE MOVING

PARTY.

2. PLAINTIFFS FAILED TO SATISFY THE NECESSARY ELEMENTS

FOR THEIR CLAIM OF UNJUST ENRICHMENT AGAINST

DEFENDANT TUARA HULL AND THE TRIAL COURT ERRED TO THE

PREJUDICE OF DEFENDANT TUARA HULL BY GRANTING

SUMMARY JUDGMENT AGAINST HER.

{¶ 9} In their first assignment of error, Defendants argue that the trial court erred

in granting summary judgment against them for unjust enrichment when there remained

a genuine issue of material fact. We agree.

II. Summary Judgment Standard

{¶ 10} Appellate review of a trial court's ruling granting or denying a party’s motion

for summary judgment is de novo. Rhododendron Holdings, LLC v. Harris, 2021-Ohio-

147, 166 N.E.3d 725, ¶ 22 (2d Dist.), citing Schroeder v. Henness, 2d Dist. Miami No.

2012-CA-18, 2013-Ohio-2767, ¶ 42. De novo review requires an appellate court to apply

the same standard that the trial court should have used without deference to the trial

court’s findings. Riverside v. State, 2016-Ohio-2881, 64 N.E.3d 504, ¶ 21 (2d Dist.).

{¶ 11} Civ.R. 56(C) provides for summary judgment where: “the pleadings,

depositions, answers to interrogatories, written admissions, affidavits, transcripts of -5-

evidence, and written stipulations of fact, if any, timely filed in the action, show that there

is no genuine issue as to any material fact and that the moving party is entitled to

judgment as a matter of law.” “Summary judgment will be granted only when there

remains no genuine issue of material fact and, when construing the evidence most

strongly in favor of the nonmoving party, reasonable minds can only conclude that the

moving party is entitled to judgment as a matter of law.” Byrd v. Smith, 110 Ohio St.3d

24, 2006-Ohio-3455, 850 N.E.2d 47, ¶ 10, citing Civ.R. 56(C). “Even the inferences to

be drawn from the underlying facts contained in the affidavits and depositions must be

construed in the nonmoving party's favor.” Turner v. Turner, 67 Ohio St.3d 337, 341,

617 N.E.2d 1123 (1993), citing Hounshell v. Am. States Ins. Co., 67 Ohio St.2d 427, 433,

424 N.E.2d 311 (1981).

{¶ 12} “The moving party carries the initial burden of affirmatively demonstrating

that no genuine issue of material fact remains to be litigated.” McAlpine v. McCloud,

2021-Ohio-2430, 175 N.E.3d 948, ¶ 11 (2d Dist.), citing Mitseff v. Wheeler, 38 Ohio St.3d

112, 115, 526 N.E.2d 798 (1988). “Once the moving party has satisfied its burden of

identifying those portions of the record that demonstrate the absence of a genuine issue

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2024 Ohio 178, Counsel Stack Legal Research, https://law.counselstack.com/opinion/timmons-v-hull-ohioctapp-2024.