Am. Express Natl. Bank v. Reynolds

Citations

• 2025 Ohio 4470

Syllabus

Default judgment; motion to void default judgment; pro se litigant; fail to file a transcript; presume regularity; App.R. 9; App.R. 4. Judgment affirmed. In the instant case, the appellant failed to include a transcript of the proceedings she challenges. Without the filing of a transcript (or a statement of the evidence or proceedings under App.R. 9(C) or an agreed statement under App.R. 9(D)), this court must presume regularity in the lower court's proceedings and affirm the lower court's judgment. Additionally, pro se litigants are presumed to have knowledge of the law and legal procedures and they are held to the same standard as litigants who are represented by counsel. Furthermore, we note that to the extent that appellant directly attacks the merits of the default judgment, this attempt is untimely and we decline to address it.