Village at Galloway Run Condominium Assn. v. Taylor

Citations

• 245 N.E.3d 1219
• 2024 Ohio 2344

Syllabus

CIV.R. 60(B) – EXCUSABLE NEGLECT – SUMMARY JUDGMENT – PRO SE LITIGANT: The trial court did not abuse its discretion in denying condominium owner's Civ.R. 60(B) motion for relief from judgment without a hearing where owner did not refute condominium association's contention that he violated HOA rules and regulations in owner's pro se answer and response in opposition to the association's summary judgment motion. After trial court entered judgment against him, owner sought relief by claiming excusable neglect based on his lack of understanding of the applicable law and legal standards due to his pro se status. Because pro se litigants are presumed to have knowledge of the law and legal procedures, such unawareness did not constitute excusable neglect under Civ.R. 60(B)(1). Judgment affirmed.