Cox v. Glenville Homes, III, L.P.

Citations

• 2026 Ohio 1053

Syllabus

Summary judgment; compulsory counterclaim; res judicata; landlord-tenant dispute; jurisdiction; housing court; forcible entry and detainer; money damages; Civ.R. 13(A); Civ.R. 12(B)(1); R.C. 1901.17; R.C. 1901.131; R.C. 1901.181. Judgment affirmed. Appellant tenant's common pleas action was barred based on principles of subject-matter jurisdiction and the doctrine of res judicata. Appellant's common pleas claims for breach of contract, unjust enrichment, negligence/breach of fiduciary duties, injunctive relief, and declaratory relief all arose from the same landlord-tenant relationship, lease, rent issues, and eviction proceedings as landlord's housing court action for forcible entry and detainer and money damages. Appellant's common pleas claims were logically related to the housing court action and were therefore compulsory counterclaims under Civ.R. 13(A). While appellant had attempted to file a counterclaim in the housing court, the counterclaim had been stricken as untimely, the housing court later entered final judgment in favor of landlord on its claims, and no attempt was made to appeal the housing court's decision.