Willoughby Eastlake City Schools v. Am. Fireworks Co.

2026 Ohio 40
CourtOhio Court of Appeals
DecidedJanuary 8, 2026
Docket2025-L-030
StatusPublished

This text of 2026 Ohio 40 (Willoughby Eastlake City Schools v. Am. Fireworks Co.) 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
Willoughby Eastlake City Schools v. Am. Fireworks Co., 2026 Ohio 40 (Ohio Ct. App. 2026).

Opinion

[Cite as Willoughby Eastlake City Schools v. Am. Fireworks Co., 2026-Ohio-40.]

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

WILLOUGHBY EASTLAKE CASE NO. 2025-L-030 CITY SCHOOLS, et al.,

Plaintiffs-Appellants, Civil Appeal from the Court of Common Pleas - vs -

AMERICAN FIREWORKS Trial Court No. 2024 CV 000164 COMPANY, et al.,

Defendants-Appellees.

MEMORANDUM OPINION AND JUDGMENT ENTRY

Decided: January 8, 2026 Judgment: Appeal dismissed

Douglas J. May, Travelers Staff Counsel Ohio, 615 Elsinore Place, Suite 610, Cincinnati, OH 45202 (For Plaintiffs-Appellants).

Dennis R. Fogarty, Davis & Young, LPA, 35000 Chardon Road, Suite 100, Willoughby Hills, OH 44094 (For Defendants-Appellees).

MATT LYNCH, P.J.

{¶1} This appeal arises from a jury trial in the Lake County Court of Common

Pleas concerning property damage allegedly caused by a fireworks display conducted on

July 4, 2019, by defendant-appellee, American Fireworks Company (“AFC”), on property

owned by plaintiff-appellant Willoughby Eastlake City Schools (“the School”) and insured

by plaintiff-appellant Travelers Property Casualty Company of America (“Travelers”). For

the reasons presented below, we dismiss the appeal for lack of a final appealable order. {¶2} Plaintiffs-appellants initially filed suit in 2021 and refiled their complaint

against AFC1 on February 5, 2024, asserting claims of negligence, negligence per se,

strict liability, res ipsa loquitur, breach of express and implied warranty, and breach of

contract. Under each cause of action, plaintiffs-appellants alleged that the roof of the

School’s property was damaged by the fireworks display; Travelers paid for the total roof

replacement at the School’s property in an amount equaling or exceeding $1,282,946.77;

the School paid its deductible in the amount of $5,000.00; and they are entitled to recover

these amounts from AFC.

{¶3} A jury trial was held over five days in February 2025. At the close of

plaintiffs-appellants’ case, the trial court orally granted AFC’s motion for a directed verdict

on plaintiffs-appellants’ breach-of-contract claim; this ruling was never reduced to writing.

The jury found that AFC did not breach a duty of care to plaintiffs-appellants and did not

violate a statute that imposes a specific duty, returning a verdict in favor of AFC on the

claims of negligence and negligence per se. The jury further found that AFC agreed to

be strictly liable to plaintiffs-appellants and proximately caused damage to the roof of the

School’s property, returning a verdict in favor of plaintiffs-appellants on their claim of strict

liability and awarding damages in the amount of $89,169.00. The trial court entered

judgment reflecting the jury verdict on February 11, 2025.

{¶4} On appeal, plaintiffs-appellants present six assignments of error

challenging the trial court’s directed verdict, several evidentiary rulings, and the jury’s

damages award. Plaintiffs-appellants contend that their substantial rights and ability to

1. Erik Bruce Johansen, an AFC employee, was also named as a defendant. Prior to the jury deliberating and reaching its verdict in this matter, the parties stipulated on the record to Johansen’s dismissal. The trial court subsequently entered an order dismissing him as a party to this litigation. PAGE 2 OF 7

Case No. 2025-L-030 prosecute their claims were affected by the trial court’s improper exclusion and limiting of

testimony and other evidence, and the evidence that was improperly excluded would have

shown AFC’s unequivocal breach of contract and the necessity and propriety of replacing,

rather than merely repairing, the roof membrane. Plaintiffs-appellants represent that

“[t]his appeal is not brought to contest liability determinations, as the jury properly found

[AFC] strictly liable per the terms of its permit application with the City of Willoughby. The

issues remaining for adjudication concern Plaintiffs-Appellants’ position that a fair trial

was not received with respect to the awarded damages for the replacement of the roof

and AFC’s breach of its contractual duties.” They contend their brief will show that “the

trial court made a series of consequential errors with respect to damages that allowed the

jury to be led astray in awarding its grossly insufficient and unfounded $89,169.00 verdict.

Plaintiffs-appellants’ are thereby entitled to retrial on the issue of damages, reversal of

the court’s granting of directed verdict on their third-party beneficiary contractual claim,

and a retrial on Count Six of their Complaint.”

{¶5} Upon review of the trial court record and the parties’ briefs in this matter, it

is apparent that the appealed entry is not a final appealable order because it does not

dispose of all claims and does not include Civ.R. 54(B) language.

{¶6} Ohio appellate courts have jurisdiction as provided by law to review and

affirm, modify, or reverse judgments or final orders of inferior courts within their district.

Section 3(B)(2), Article IV of the Ohio Constitution; see also R.C. 2505.03. “If a lower

court’s order is not final, then an appellate court does not have jurisdiction to review the

matter, and the matter must be dismissed.” Lloyd v. Thornsbery, 2018-Ohio-2580, ¶ 5

(11th Dist.), citing Gen. Acc. Ins. Co. v. Ins. Co. of N. Am., 44 Ohio St.3d 17, 20 (1989).

PAGE 3 OF 7

Case No. 2025-L-030 {¶7} Ohio’s statutory definition of “final order” provides multiple categories of final

appealable orders, only one of which is applicable here; namely, “An order that affects a

substantial right in an action that in effect determines the action and prevents a judgment.”

R.C. 2505.02(B)(1). When there are multiple claims at issue in an action, the trial court

must also comply with Civ.R. 54(B), which requires that “[w]hen more than one claim for

relief is presented in an action . . . the court may enter final judgment as to one or more

but fewer than all of the claims or parties only upon an express determination that there

is no just reason for delay.” (Emphasis added.) In the absence of this Civ.R. 54(B)

language, an order that adjudicates fewer than all the claims does not terminate the action

as to any of the claims or parties and is subject to revision at any time. Id. Accordingly,

in a multi-claim action, an order that fails to comply with Civ.R. 54(B) is not a final

appealable order because it does not determine the action and prevent a judgment. See

Chef Italiano Corp. v. Kent State University, 44 Ohio St.3d 86 (1989), syllabus (“An order

of a court is a final, appealable order only if the requirements of both Civ.R. 54(B), if

applicable, and R.C. 2505.02 are met.”).

{¶8} The February 11, 2025 judgment appealed herein addresses the jury

verdicts on the claims of negligence, negligence per se, and strict liability, but it does not

address the claims of res ipsa loquitur, breach of warranty, or breach of contract. The

judgment entry does not include Civ.R. 54(B) language. Moreover, plaintiffs-appellants

concede that the directed verdict on the breach of contract claim, which was entered orally

at trial, was never journalized. See Civ.R. 50(E) (“When in a jury trial a court directs a

verdict . . ., the court shall state the basis for its decision in writing prior to or simultaneous

PAGE 4 OF 7

Case No. 2025-L-030 with the entry or judgment.

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Lloyd v. Thornsberry
2018 Ohio 2580 (Ohio Court of Appeals, 2018)
Whitaker-Merrell Co. v. Carl M. Geupel Construction Co.
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Bluebook (online)
2026 Ohio 40, Counsel Stack Legal Research, https://law.counselstack.com/opinion/willoughby-eastlake-city-schools-v-am-fireworks-co-ohioctapp-2026.