Akarah v. Ohio Dept. of Rehab. & Corr.

Citations

• 253 N.E.3d 712
• 2024 Ohio 4499

Syllabus

Judgment affirmed. The trial court properly granted Ohio Department of Rehabilitation and Correction's (\ODRC\) motion for summary judgment because plaintiff's defamation claims were subject to either an absolute or qualified privilege, and plaintiff failed to present any Civ.R. 56 evidence demonstrating that ODRC made the qualifiedly privileged statements with actual malice. Plaintiff did not file a motion to disqualify the trial court's magistrate for bias, the trial court was not required to hold an oral hearing on the motion for summary judgment, and the trial court properly considered the Civ.R. 56 evidence in the record. The trial court addressed the reason plaintiff was terminated from his position and the court did not err by failing to address irrelevant facts. The trial court was not required to ask the parties to produce evidence and plaintiff did not file a Civ.R. 56(F) motion.