Freeman v. Todd Deegan Mgt., Inc.

Citations

• 2019 Ohio 1530

Syllabus

Res Judicata -- Under the doctrine of res judicata, a valid, final judgment rendered upon the merits bars all subsequent actions based upon any claim arising out of the same transaction or occurrence that was the subject matter of a previous action. The Ohio Supreme Court has identified four elements necessary to bar a claim under the doctrine of res judicata: (1) there is a final, valid decision on the merits by a court of competent jurisdiction (2) the second action involves the same parties or their privies as the first (3) the second action raises claims that were or could have been litigated in the first action and (4) the second action arises out of the transaction or occurrence that was the subject matter of the previous action. In Deegan's second cause of action for money damages, Freeman signed a consent entry agreeing to judgment in Deegan's favor for $700 to be paid in monthly installments. The consent entry was reduced to a final judgment on March 2, 2016. The record indicates that Freeman made an installment payment on April 11, 2016 in the amount of $35, which is a clear indication that matter had been addressed and resolved. As a result, Freeman is barred from asserting or relitigating this claim in the present action.