Rodriguez v. Catholic Charities Corp.

Citations

• 2025 Ohio 4840

Syllabus

Expert witness testimony; admissibility; causation; speculation; directed verdict; vicarious liability; respondeat superior; apportionment of damages; consent judgment entry; negligent hiring, training, and supervision; wrongful death; survival action; failure to report child abuse or neglect. The Estate of a deceased boy sought damages for claims, including wrongful death, a survival action, failure to report child abuse or neglect and negligent hiring, training and supervision, against Catholic Charities, a community service provider hired by the Cuyahoga County Department of Children and Family Services to provide services to the boy's mother and her family. The boy's mother and her boyfriend pled guilty to involuntary manslaughter of the boy after law enforcement discovered his body buried in the backyard of his home. Evidence in the record tends to show that the boy died of starvation. The Catholic Charities employee who was assigned to this case pled guilty to food stamp fraud for purchasing the boy's mother's food stamps for a reduced price. The Catholic Charities employee and the Estate entered into a consent judgment entry in which the employee admitted liability for the boy's death. After a jury trial, the court granted a directed verdict on all claims other than Catholic Charities' negligent hiring, training and supervision of its employee who admitted liability. The court found, as a matter of law, that Catholic Charities was not vicariously liable for the negligence of its employee. The jury found in favor of the Estate and against Catholic Charities and awarded the Estate $12 million. After the court applied the statutory cap on non-economic damages, as well as apportionment under the empty-chair defense, the damage award was reduced to $740,000. The Estate appealed. We find that the trial court erred by refusing to acknowledge the consent judgment entry; ruling that the consent judgment entry was inadmissible at trial; ruling that, as a matter of law,