Epcon Communities Franchising, L.L.C. v. Wilcox Dev. Group, L.L.C.

Citations

• 2024 Ohio 4989

Syllabus

Civil law—Preemption—Judicial restraint—Trial court erred by dismissing case on theory that if a state-law cause of action for contribution existed, it was preempted by federal law—No party had argued for federal preemption, constitutional avoidance prevents courts from answering a constitutional question unless necessary to do so, and whether federal preemption applies is a hypothetical question—Judgment reversed and cause remanded to trial court.