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Northwest Bank v. Edwards

2026-08-20

Summary

Holding. The trial court erred in entering default judgment against Edwards using the statutory interest rate instead of the 13.04 percent per annum rate agreed to in the promissory note. The judgment is vacated and remanded to the trial court to enter a corrected default judgment reflecting the contractual interest rate.

Northwest Bank sued Jacob Edwards for nonpayment of a vehicle loan and obtained a default judgment without Edwards filing a response. Although the trial court ruled in Northwest Bank's favor, it applied the statutory interest rate to the judgment rather than the contractual rate specified in the promissory note that Edwards had signed. Northwest Bank appealed, arguing that under Ohio law, when a written contract specifies an interest rate, that rate controls and the creditor is entitled to interest at the agreed rate rather than the statutory default rate. The appellate court reviewed the matter de novo and found that the promissory note clearly set the interest rate at 13.04 percent per annum, both before and after judgment, and that Northwest Bank's complaint and default motion specifically requested this contractual rate. The trial court erred by disregarding the express contractual terms and the relief requested in the pleadings.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether a trial court may apply statutory interest instead of contractual interest when the written contract specifies a different rate
  • Interpretation and application of R.C. 1343.03 regarding judgment interest on promissory notes
  • Whether a creditor's complaint and default motion requesting contractual interest create binding requirements on the trial court

Procedural posture

Northwest Bank appealed from the trial court's default judgment order entered in Cuyahoga County Common Pleas Court, challenging the interest rate applied to the award.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

[Cite as Northwest Bank v. Edwards, 2026-Ohio-3240.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT

COUNTY OF CUYAHOGA

NORTHWEST BANK, :

Plaintiff-Appellant, :

No. 116239

v. :

JACOB R. EDWARDS, :

Defendant-Appellee. :

JOURNAL ENTRY AND OPINION

JUDGMENT: VACATED AND REMANDED

RELEASED AND JOURNALIZED: August 20, 2026

Civil Appeal from the Cuyahoga County Court of Common Pleas

Case No. CV-25-111402

Appearances:

Stultz Law, Ltd., and Michael D. Stultz, for appellant.

KATHLEEN ANN KEOUGH, J.:

Plaintiff-appellant Northwest Bank brings this appeal challenging the

trial court’s decision granting a default judgment against Jacob R. Edwards

pertaining to a promissory note that he signed with Northwest Bank. According to

the court’s judgment entry, Northwest Bank is entitled to “$13,835.00, accrued

interest in the amount of $1,976.06[] plus interests at the statutory rate from date

of judgment and costs.” Despite judgment in its favor, Northwest Bank contends that the trial court erred as a matter of law by awarding statutory interest rather than

interest as dictated by the terms of the promissory note. Upon review, this court

agrees with Northwest Bank; we vacate the default judgment order entered against

Edwards and order this case remanded for the trial court to issue a judgment entry

correctly reflecting the interest rate as agreed to in the promissory note and

requested in Northwest Bank’s complaint and motion for default judgment.

Northwest Bank filed a complaint seeking judgment from Edwards

for nonpayment of his vehicle loan. Edwards did not file any answer or response,

and on August 6, 2025, Northwest Bank filed a motion for default judgment. The

court issued notice that the default hearing was scheduled for January 22, 2026, by

telephone. The next month, the court granted Northwest Bank’s motion for default

judgment from which Northwest Bank timely filed this appeal.

Because Northwest Bank asserts that the trial court erred in granting

default judgment at the statutory interest rate rather than the interest rate agreed to

in the promissory note that was attached to the complaint and motion for default

judgment, we review this matter de novo. See, e.g., Midwestern Auto Sales v.

Lattimore, 2015-Ohio-53, ¶ 23 (12th Dist.).

R.C. 1343.03 dictates that the statutory interest rate is to be utilized

for interest on judgments, “unless a written contract provides a different rate of

interest in relation to the money that becomes due and payable, in which case the

creditor is entitled to interest at the rate provided in that contract.”

On this record, we find that the terms of the promissory note attached

to the complaint set pre- and postjudgment interest at 13.04 percent per annum

from and after November 7, 2024. Northwest Bank did not ask for judgment interest

at the statutory rate; it asked for judgment interest pursuant to the terms of the

contract. Accordingly, we sustain Northwest Bank’s sole assignment of error and

find that the court erred in failing to award the interest rate provided for in the

agreement between the parties where Northwest Bank’s complaint and motion for

default specifically prayed for the interest agreed to in the promissory note.

For the sake of thoroughness, we sua sponte note that Northwest

Bank’s complaint and default-judgment motion also specifically asked for $281.52

in late fees. The trial court did not award the late fees, but Northwest Bank, however,

has not assigned this omission as error or addressed it on appeal. We accordingly

do not award the $281.52 in late fees as designated by the complaint and consider

the amount waived.

Judgment vacated and case remanded to the lower court for further

proceedings consistent with this opinion. The trial court is ordered to enter default

judgment against Edwards correcting the interest rate to the rate agreed to in the

promissory note: 13.04 percent per annum from and after November 7, 2024.

It is ordered that appellant recover from appellee costs herein taxed.

The court finds there were reasonable grounds for this appeal.

It is ordered that a special mandate be sent to said court to carry this judgment

into execution.

A certified copy of this entry shall constitute the mandate pursuant to Rule 27

of the Rules of Appellate Procedure.

KATHLEEN ANN KEOUGH, JUDGE

MARY J. BOYLE, P.J., and

TIMOTHY W. CLARY, J., CONCUR