The Ohio Court of Appeals has upheld a lower court's ruling against tenants Naeem Triplett and Degan Smith in a dispute with their former landlord, Lynnboro LLC. The court denied the tenants' request for relief from a judgment entered against them after they failed to appear for a scheduled trial. This decision, made on September 29, 2026, could impact how tenants approach legal disputes with landlords in the future.
The case began when Triplett and Smith filed a complaint against Lynnboro LLC on October 16, 2025. They sought a monetary judgment related to their former tenancy at a Toledo property. After an unsuccessful mediation session on February 9, 2026, the case was set for trial on March 12, 2026. However, the tenants did not appear in court on the scheduled date, leading to a judgment against them.
During the trial, Lynnboro LLC was represented by counsel and presented evidence supporting its counterclaim against the tenants. The court awarded Lynnboro LLC $2,048.39, plus interest and costs. Following the trial, Triplett and Smith filed a motion for relief from judgment under Ohio Civil Rule 60(B), claiming their absence was due to car trouble that constituted excusable neglect.
The trial court denied their motion for relief on March 19, 2026, stating that the tenants had not made any effort to contact the court regarding their absence and had not provided sufficient evidence to support their claim of excusable neglect. The court noted that the tenants failed to include any documentation or sworn affidavits with their motion. The court ruled, "No grounds exist under Civ.R. 60(B), including excusable neglect, which entitle Plaintiffs to relief."
Triplett and Smith subsequently filed a supplemental memorandum and affidavit on March 27, 2026, which included a towing invoice and an explanation of their car troubles. However, the trial court deemed this filing moot since their initial motion had already been denied. The tenants then appealed the ruling, arguing that the trial court had acted too quickly in denying their motion before the response deadline had passed.
In its ruling, the Ohio Court of Appeals, led by Judge Myron C. Duhart, affirmed the lower court's decision. The court explained that under Civil Rule 60(B), a party must demonstrate a meritorious defense, entitlement to relief under one of the specified provisions, and compliance with the time requirements. The court found that the tenants failed to meet these criteria.
The court noted, "The allegation of operative facts must be of such evidentiary quality as affidavits, depositions, answers to interrogatories, written admissions, written stipulations, or other sworn testimony." Since the tenants relied on unsworn allegations, the court concluded that the trial court acted appropriately in denying their motion.
The ruling has implications for tenants and landlords in Ohio. It emphasizes the importance of appearing in court and providing adequate evidence when seeking relief from judgments. The court's decision also reinforces the requirement that tenants must adhere to procedural rules and deadlines in legal proceedings.
Moving forward, the ruling may deter tenants from filing frivolous motions without proper documentation. It also serves as a reminder that failure to appear in court can have significant consequences, including losing a case outright. The court's decision may influence how tenants approach disputes with landlords and the importance of being prepared for legal proceedings.
As for what’s next, it is unclear whether Triplett and Smith will seek further appeals. The court's ruling appears final unless new grounds for appeal arise. There are no related cases pending at this time. The outcome of this case may serve as a precedent for similar disputes in the future.