Duff v. Centrome, Inc.

Citations

• 2023 Ohio 1321

Syllabus

The trial court erred in imposing sanctions for frivolous conduct under R.C. 2323.51 when the parties had not moved for sanctions under the statute and the trial court failed to comply with the notice and hearing requirements before awarding frivolous conduct sanctions. Although the trial court found appellant had committed discovery violations under Civ.R. 37(C), the court failed to issue a final appealable order imposing sanctions under Civ.R. 37, thereby preventing appellate review.