Public-domain · open source
OpenJurist

117 Ohio St. 3d 92

Pruszynski v. Reeves

Ohio Supreme Court

Decided February 14, 2008

Ohio Supreme Court · decided 2008-02-14

Key passage — most relied on by later courts

“"upon motion of any party to a civil action that is based on tortious conduct, that has not been settled by agreement of the parties, and in which the court has rendered a judgment, decree, or order for the payment of money, the court determines at a hearing held subsequent to the verdict or decision in the action that the party required to pay the money failed to make a good faith effort to settle the case and that the party to whom the money is to be paid did not fail to make a good faith effort to settle the case[.]"”

quoted by 2 later decisions, including Moga v. Crawford, 23965 (5-7-2008), Nguyen v. Chen

“a trial court must set a date certain for an evidentiary hearing before ruling on an R.C. 1343.03(C) motion for prejudgment interest.”

quoted by 2 later decisions, including Kane v. Saverko, 23908 (3-26-2008), Bolen v. Mohan

Good law ✅— No negative treatment on recordhow we know

Decided 2008-02-14

How this case has been cited

Cited by 41 later decisions — most recently March 2024 · most notably Disciplinary Counsel v. Pullins (2010), Beverage Distributors, Inc. v. Miller Brewing Co. (2012)

2 federal appellate · 39 state decisions

300200820102020decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

Lanzinger, J.,

¶1concurring in part and dissenting in part.

¶2{¶ 23} I concur in the judgment of reversal and remand to the trial court because the court of appeals exceeded the scope of its authority in awarding prejudgment interest to the Pruszynskis. I cannot, however, read the plain text of the statute to require a hearing whenever a motion is filed.

¶3(¶ 24} By its language, R.C. 1343.03(C)(1) lodges discretion in the judge. “If, upon motion , the court determines at a hearing held subsequent to the verdict or decision in the action that the party required to pay the money failed to make a good faith effort to settle the case and that the party to whom the money is to be paid did not fail to make a good faith effort to settle the case, interest on the judgment, decree, or order shall be computed The statute does not say, “A court shall hold a hearing upon the filing of a motion

¶4{¶ 25} The majority recognizes that the statutory procedure for a trial court’s handling of motions for prejudgment interest was subject to differing interpretation by the courts of appeals. In resolving the issue, the majority holds that the trial court has discretion in determining the type of “evidentiary hearing” to be held when a motion for prejudgment interest is filed by a party. But in doing so, it has ignored the statute that allowed a trial judge the discretion to initially decide whether a hearing should be granted at all.

¶5{¶ 26} Several good reasons are set forth for requiring the court to set a date certain for an evidentiary hearing on a motion for prejudgment interest. Nevertheless, the language of R.C. 1343.03(C)(1) is not one of them. I respectfully disagree with the analysis on this point.

/117/ohiost3d/92 · .json · Public domain