Allan v. Allan

Citations

• 2026 Ohio 1187

Syllabus

Judgment notwithstanding the verdict (\JNOV\); JNOV; fraudulent transfer; statute of limitations; Civ.R. 50(B); R.C. 1336.09; R.C. 1336.06; reasonably could have discovered; discovery rule; manifest weight of the evidence; perfection; accrual; domestic relations; divorce. In a fraudulent-transfer case, the trial court erred in granting judgment notwithstanding the verdict in favor of defendants on statute-of-limitations grounds. The jury was entitled to weigh the competing evidence on whether and when the transfers occurred and whether the plaintiff reasonably could have discovered the transfers. The trial court exceeded its authority under Civ.R. 50(B) by substituting its own judgment for that of the jury's by improperly applying a manifest-weight-of-the-evidence standard rather than a sufficiency-of-the-evidence standard. The evidence that the jury considered in determining the accrual date of the action for statute-of-limitations purposes was sufficient to support its ruling.