The Ohio Court of Appeals recently reversed a lower court's decision that enforced a settlement agreement between Champion Waterproofing, Inc. and RWC Rentals. This ruling, issued on June 15, 2026, affects how settlement agreements are interpreted and enforced in Ohio, particularly regarding the burden of proof required to show compliance with such agreements.
The case, Champion Waterproofing, Inc. v. RWC Rentals, was filed under docket number 2025-T-0067. The dispute arose after Champion Waterproofing sought to enforce a settlement agreement that required RWC Rentals to pay $10,000 for work performed on a rental property. The outcome of this case is significant for businesses and contractors involved in similar disputes over settlement agreements.
Background
Champion Waterproofing, Inc. is a company that specializes in waterproofing and related services. RWC Rentals, owned by Robert Cregar, operates rental properties. The conflict began in 2022 when Champion filed a complaint in the Mahoning County Court of Common Pleas, seeking payment for work done on RWC's property. The case was later transferred to the Trumbull County Court of Common Pleas.
During mediation, the parties reached a settlement agreement in December 2023. Under this agreement, RWC was to pay Champion $10,000, with $5,000 due immediately and the other $5,000 held in trust. Champion agreed to perform specific work, including attaching window wells and remedying electrical issues, but the agreement noted that the work would not be warrantied due to concerns about a buried drainpipe potentially failing.
The Ruling
On August 1, 2024, the trial court dismissed the case with prejudice, allowing for the enforcement of the settlement agreement. However, in October 2024, Champion filed a motion to enforce the agreement, claiming it had completed the work but that RWC failed to pay the remaining $5,000. Following an evidentiary hearing, the trial court ruled in favor of Champion, ordering RWC to pay the outstanding amount.
RWC appealed the ruling, arguing that the trial court had made a reversible error by enforcing the settlement agreement. The Ohio Court of Appeals, led by Judge Eugene A. Lucci, reviewed the case and found that Champion had not provided sufficient evidence to prove it had completed all required work under the settlement agreement. The court stated, "Champion failed to meet its burden of production on the element of its claim that it had performed its duties under the settlement agreement." As a result, the court reversed the trial court's decision and remanded the case for further proceedings.
Impact
This ruling emphasizes the importance of providing clear evidence when enforcing settlement agreements. The court's decision highlights that the burden of proof lies with the party seeking enforcement. In this case, Champion's inability to demonstrate that it completed all aspects of the settlement agreement led to the reversal of the trial court's ruling.
The implications of this ruling extend beyond the parties involved. It sets a precedent for how courts may interpret and enforce settlement agreements in Ohio, particularly in cases where one party claims that the other has not fulfilled their obligations. Businesses and contractors may need to be more diligent in documenting their compliance with settlement terms to avoid similar disputes.
What's Next
The case has been remanded to the trial court for further proceedings consistent with the appellate court's opinion. It remains to be seen whether Champion will present additional evidence to support its claims or if the parties will seek a new resolution outside of court. Additionally, RWC may have grounds to counter any further claims made by Champion regarding the settlement agreement.