Djurin v. Ginley

Citations

• 2023 Ohio 1041

Syllabus

Landlord tenant deposit rent R.C. 5321.07 escrow distribution magistrate's decision objections untimely Civ.R. 53(D)(3)(b)(i) Civ.R. 53(D)(5) Civ.R. 53(D)(4)(c) pro se plain error civil exceptional circumstances. Affirmed the judgment of the trial court in a landlord-tenant dispute involving rent deposited with the court pursuant to R.C. 5321.07. Pro se litigants are held to the same standard as litigants represented by counsel. Because the pro se defendant did not timely object to a magistrate's decision on the distribution of the escrowed funds, he waived any challenge except for a claim of plain error. In a civil case, plain-error review is disfavored. The defendant failed to raise plain error, and the case did not present exceptional circumstances warranting application of the plain-error doctrine.