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Oliver v. Cobco Ents., L.L.C.

2026-08-26

Summary

Holding. The trial court's grant of summary judgment in favor of the property owners (McDonald's) is affirmed because Oliver failed to establish admissible evidence of their notice of the hazard. The trial court's grant of summary judgment in favor of Proline Striping Service is reversed and remanded because the open-and-obvious doctrine does not apply to independent contractors, and Oliver's expert opinion creates a material question of fact regarding Proline's liability.

Yolanda Oliver slipped and fell in a McDonald's parking lot on painted stripes during wet conditions. She sued the property owners (Cobco Enterprises and Pickard Enterprises, collectively referred to as McDonald's) and Proline Striping Service, which had painted the lot. Oliver claimed the painted letters became slippery when wet and that the property owners had notice of similar prior incidents through an employee's statement.

The trial court granted summary judgment to both defendants. The appellate court upheld the dismissal against McDonald's because Oliver failed to establish admissible evidence that the company had knowledge of the dangerous condition. The employee whose alleged statement could have shown notice was never identified, and Oliver could not satisfy the requirements for admission of the statement as an admission by a party opponent.

However, the court reversed summary judgment against Proline, finding that the open-and-obvious doctrine does not protect independent contractors from liability and that Oliver's expert opinion regarding the dangerousness of the painted surface was sufficient to create a genuine issue of material fact for trial.

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

Key issues

  • Whether the open-and-obvious doctrine shields independent contractors from negligence liability
  • Whether an unidentified employee's statement qualifies as an admission by a party opponent under evidence rules
  • Whether an expert's opinion that painted parking lot stripes become unreasonably slippery when wet creates a material factual question for trial

Procedural posture

A slip-and-fall plaintiff appealed from the trial court's grant of summary judgment in favor of both the property owners and the painting contractor who performed the work.

Authorities cited

Opinion

majority opinion

[Cite as Oliver v. Cobco Ents., L.L.C., 2026-Ohio-3325.]

IN THE COURT OF APPEALS

FIRST APPELLATE DISTRICT OF OHIO

HAMILTON COUNTY, OHIO

YOLANDA OLIVER, : APPEAL NO. C-250541

TRIAL NO. A-2203192

Plaintiff-Appellant, :

vs. :

JUDGMENT ENTRY

COBCO ENTERPRISES, LLC, d.b.a :

MCDONALDS,

:

PICKARD ENTERPRISES, LLC,

:

and

:

PROLINE STRIPING SERVICE, INC.,

:

Defendants-Appellees,

:

and

:

MOLINA HEALTHCARE OF

MICHIGAN, :

Defendant. :

This cause was heard upon the appeal, the record, the briefs, and arguments.

For the reasons set forth in the Opinion filed this date, the judgment of the trial court is affirmed in part and reversed in part, and the cause is remanded.

Further, the court holds that there were reasonable grounds for this appeal, allows no penalty, and orders that costs be taxed 50% to Appellant and 50% to Appellee Proline.

The court further orders that (1) a copy of this Judgment with a copy of the Opinion attached constitutes the mandate, and (2) the mandate be sent to the trial court for execution under App.R. 27.

OHIO FIRST DISTRICT COURT OF APPEALS

To the clerk:

Enter upon the journal of the court on 8/26/2026.

Pursuant to App.R. 30, the clerk is directed to send all parties, or their counsel if represented, a copy of the court’s judgment and note such action on the docket.

By:_______________________

Administrative Judge

[Cite as Oliver v. Cobco Ents., L.L.C., 2026-Ohio-3325.]

IN THE COURT OF APPEALS

FIRST APPELLATE DISTRICT OF OHIO

HAMILTON COUNTY, OHIO

YOLANDA OLIVER, : APPEAL NO. C-250541

TRIAL NO. A-2203192

Plaintiff-Appellant, :

vs. :

OPINION

COBCO ENTERPRISES, LLC, d.b.a :

MCDONALDS,

:

PICKARD ENTERPRISES, LLC,

:

and

:

PROLINE STRIPING SERVICE, INC.,

:

Defendants-Appellees,

:

and

:

MOLINA HEALTHCARE OF

MICHIGAN, :

Defendant. :

Civil Appeal From: Hamilton County Court of Common Pleas

Judgment Appealed From Is: Affirmed in Part, Reversed in Part, and Cause Remanded

Date of Judgment Entry on Appeal: August 26, 2026

O’Conner Acciani & Levy, LPA, and Robert B. Acciani, for Plaintiff-Appellant,

Weston Hurd, LLP, Kaitlyn L. Madigan and Steven G. Carlino, for DefendantsAppellees Cobco Enterprises, LLC, and Pickard Enterprises, LLC,

Smith, Warnecke, Meredith & Clark Law, LLC, Dalton J. Smith and J. Alan Smith, for Defendant-Appellee Proline Striping Service, Inc.

[Cite as Oliver v. Cobco Ents., L.L.C., 2026-Ohio-3325.]

MOORE, Judge.

{¶1} Plaintiff-appellant Yolanda Oliver appeals from the judgment of the

Hamilton County Court of Common Pleas granting defendants-appellees’ motions for

summary judgment on the issue of whether the defendants were liable for Oliver’s slip

and fall.

{¶2} In her sole assignment of error, Oliver asserts that the trial court erred

in granting summary judgment to three parties. Two parties, Cobco Enterprises, LLC,

d.b.a. McDonalds (“Cobco”) and Pickard Enterprises, LLC, (“Pickard”) are the

premises owners, and Proline Striping Service, Inc., (“Proline”), is the company that

performed painting services on the parking lot, which was then owned by Cobco.

Cobco and Pickard will jointly be referred to as “McDonalds” hereafter. For the reasons

set forth below, the trial court’s grant of summary judgment in favor of McDonalds is

affirmed and its grant of summary judgment in favor of Proline is reversed.

I. Factual and Procedural History

{¶3} In September 2022, Oliver filed a complaint alleging that she fell in a

parking lot. Her complaint alleged that the injuries sustained were the result of

defendants negligently maintaining the premises, creating a dangerous condition,

failing to ensure the premises was free of dangerous conditions, and failing to correct

a known dangerous condition on the premises.

{¶4} During Oliver’s deposition, she explained that on October 23, 2017, she

and her family were driving from Michigan to Alabama when they stopped at a

McDonalds in Cincinnati, Ohio. Oliver recalled that it had been raining sporadically

that day and the parking lot was wet. Oliver testified that although she usually used an

electric wheelchair because of her mobility issues, she used a cane the day of the fall.

Oliver stated that while she was walking through the parking lot, across the “driveOHIO FIRST DISTRICT COURT OF APPEALS

thru” lane, her cane slipped on the word “thru” painted on the ground and she fell.

Oliver injured her right arm in the fall.

{¶5} During her deposition, Oliver testified that while she was on the ground

after she slipped, a McDonalds employee approached and said that “someone recently

had a similar incident.” Oliver did not otherwise identify this individual.

{¶6} Heather Kephart, Pickard’s office manager, testified in an affidavit that

she reviewed the company records for the year prior to Oliver’s fall and found no

reports or information concerning any prior slip-and-fall incidents.

{¶7} Jared Marr, the owner of Proline, testified in an affidavit that Proline

was hired by Pickard to paint the parking lot in July 2017. Marr also stated that Proline

used paint manufactured by the Sherwin-Williams Company, which was specifically

designed for traffic marking, and that the paint’s composition was not altered or

modified in any way.

{¶8} In March 2024, in response to Oliver’s complaint, McDonalds moved

for summary judgment and Proline filed its own motion for summary judgment. Oliver

then filed responses in opposition to both summary-judgment motions, supported

with a report from her expert, David Collette. Proline filed a motion to strike the report

because it claimed the report was deficient under Evid.R. 702. Following this, Oliver

submitted a motion to supplement the report and did so by attaching Collette’s

affidavit to the report. The substance of the report remained unchanged.

{¶9} The trial court denied both motions for summary judgment and ordered

that further discovery was necessary regarding Collette’s expert report. The trial court

found that Collette’s expert report relied heavily on hearsay and was deficient under

Evid.R. 702. The court, however, viewed the report as a preliminary document that

needed a “meticulous explanation.” After denying the motions for summary judgment,

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OHIO FIRST DISTRICT COURT OF APPEALS

the court set the trial date for September 30, 2024.

{¶10} Oliver did not supplement the substance of the expert report following

the trial court’s order. On August 30, 2024, Proline filed a motion in limine regarding

the expert report, asserting that the report should be barred at trial because Oliver had

not supplemented the report with information necessary to cure the Evid.R. 702

deficiencies within 30 days of trial.

{¶11} In December 2024, the trial court held a Daubert hearing regarding

Oliver’s expert. See Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579, 589

(1993) (holding that courts must ensure that any scientific testimony and evidence

that is to be admitted is both relevant and reliable); see also Terry v. Caputo, 2007-Ohio-5023, ¶ 24 (recognizing that Daubert’s reliability and relevance requirements

have been adopted by Ohio courts). The trial court then granted Proline’s and

McDonalds’s requests for another opportunity to file motions for summary judgment.

The court’s entry stated,

In light of this, the Court GRANTS the motions to file motions for

summary judgment of which the standards under Evid. R. 702 and

Daubert may be directly at issue.

The trial court did not issue an order regarding the use of the expert report following

the Daubert hearing.

{¶12} In January 2025, Proline and McDonalds filed their second motions for

summary judgment. In its motion, Proline argued it was entitled to summary

judgment on two bases: first, Oliver failed to surmount the open-and-obvious

doctrine, and second, she failed to support her claim that the letters in the parking lot

were more dangerous than other areas of the parking lot. The motion filed on behalf

of McDonalds argued that Oliver did not introduce any evidence establishing that it

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created the alleged hazard or that it had actual notice of the hazard. McDonalds also

argued that the condition was open and obvious.

{¶13} The trial court entered an order granting the motions for summary

judgment in August 2025. The trial court found that Oliver’s claims against

McDonalds were barred by the open-and-obvious doctrine and that, even if the hazard

was not open and obvious, there was no duty owed under premises-liability theory.

The trial court also found that the open-and-obvious doctrine barred Oliver’s claims

against Proline because Proline did not create a dangerous condition and the injury

was not reasonably foreseeable.

{¶14} This appeal followed.

II. Analysis

{¶15} In her sole assignment of error, Oliver contends that the trial court erred

in granting summary judgment in favor of McDonalds and Proline.

A. The Court Properly Excluded Hearsay Testimony Regarding

McDonalds

{¶16} A trial court’s grant of summary judgment is reviewed de novo. R&R

Family Invests. v. Plastic Moldings Corp., 2016-Ohio-8125, ¶ 7 (1st Dist.), citing

Schmidt v. Village of Newtown, 2012-Ohio-890, ¶ 6 (1st Dist.). Summary judgment is

appropriately granted when there exists no genuine issue of material fact, the party

moving for summary judgment is entitled to judgment as a matter of law, and the

evidence, when viewed in favor of the nonmoving party, permits only one reasonable

conclusion that is averse to that party. Id.

{¶17} A trial court’s evidentiary rulings, including its determination on the

admissibility of hearsay, are reviewed under an abuse-of-discretion standard. Kelley

v. Horton, 2025-Ohio-5252, ¶ 19 (1st Dist.). Under this deferential standard, a

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reviewing court will not disturb the trial court’s decision absent the court exercising

its judgment in an “unwarranted way, in regard to a matter over which it has

discretionary authority.” Worley v. Durrani, 2025-Ohio-2245, ¶ 13 (1st Dist.), citing

Adams v. Durrani, 2022-Ohio-60, ¶ 16 (1st Dist.).

{¶18} Oliver argues that the court’s grant of summary judgment in favor of

McDonalds was inappropriate because the hazard was not open and obvious and

McDonalds was given notice of the parking lot’s dangerous condition by an employee.

McDonalds argues that summary judgment was appropriate under the open-andobvious doctrine. We do not need to determine if there was a material question of fact

regarding whether the hazard was open and obvious because Oliver failed to introduce

any admissible evidence that McDonalds had notice of the dangerous condition.

{¶19} To establish a claim for personal injuries caused by a property owner’s

negligence, a plaintiff must establish either “(1) that a defendant through its officers

or employees is responsible for the hazard complained of; or (2) that at least one of

such persons have actual knowledge of the hazard and neglect to give adequate notice

of its presence or remove it promptly; or (3) that such danger exists for a sufficient

length of time reasonably to justify the inference that the failure to warn against it or

remove it is attributable to a want of ordinary care.” Besack v. Kroger Co., 2023-Ohio2497, ¶ 52 (10th Dist.), quoting Johnson v. Wagner Provision Co., 141 Ohio St. 584,

589 (1943).

{¶20} Here, Oliver argues that there is a material question of fact as to whether

McDonalds had notice based on her claim that a McDonalds’s employee told her that

the owners knew of a similar accident in the recent past. The trial court found,

however, that this testimony was inadmissible hearsay and could not be used to

establish notice. We agree.

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OHIO FIRST DISTRICT COURT OF APPEALS

{¶21} Hearsay is any out-of-court statement offered to prove the truth of the

matter asserted and is generally inadmissible. State v. Wilson, 2026-Ohio-1178, ¶ 4

(1st Dist.). However, Evid.R. 801(D)(2) provides that a statement by a party opponent

is not hearsay. State v. Durbin, 2025-Ohio-5724, ¶ 59 (1st Dist.), citing Evid.R.

801(D)(2). If a party seeks to have a statement that is otherwise hearsay admitted

pursuant to Evid.R. 801(D)(2), that party has the burden of establishing that the

statement “was made by an agent or employee of the party-opponent, during the

existence of the relationship, concerning a matter within the scope of employment or

agency.” Davis v. Sun Refining & Marketing Co., 109 Ohio App.3d 42, 53 (2d Dist.

1996); accord RWS Bldg. Co. v. Freeman, 2005-Ohio-6665, ¶ 37 (4th Dist.) (holding

that statements by an unidentified employee are inadmissible under Evid.R.

801(D)(2)).

{¶22} Oliver contends that McDonalds possessed actual knowledge of the

allegedly dangerous condition based on her claim that while she was on the ground

after her fall, a McDonalds employee approached her and stated that “someone

recently had a similar incident” and that management was told it was not a good idea

to have “that paint” in a walkway. Notably, Oliver never obtained the name of the

individual who allegedly made the statement about McDonalds’s knowledge of the

condition. Oliver testified that she never saw the individual until being presented a

photograph during her deposition that supposedly showed him blurred in the

background. The photograph contained nothing identifying the individual as a

McDonalds employee. For its part, McDonalds submitted the affidavit of its office

manager, Kephart, who testified that she reviewed the company’s records for the year

prior to the fall and found no records of any other slip and falls occurring on the

property.

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OHIO FIRST DISTRICT COURT OF APPEALS

{¶23} Oliver argues that the alleged employee’s statement is admissible under

Evid.R. 801(D)(2) as an admission by a party opponent. Oliver, however, failed to

identify the declarant, “by name or position, or established that the statement

concerned a matter within the scope of that person’s employment.” Shreves v. Meridia

Health Sys., 2006-Ohio-5724, ¶ 24 (8th Dist.), citing RWS Bldg. Co. at ¶ 38. Moreover,

Oliver presented no admissible evidence that established the declarant’s identity,

employment status, or authority to speak on matters relating to premises safety. As a

result, Oliver failed to lay the necessary foundation for admission of the alleged

statement under Evid.R. 801(D)(2), rendering the statement inadmissible hearsay.

Thus, the trial court did not abuse its discretion in excluding the alleged statement.

{¶24} Absent admissible evidence establishing that McDonalds had actual

knowledge of the alleged hazard and failed to provide a warning or remedy it, Oliver

has failed to demonstrate a genuine issue of material fact.

{¶25} Accordingly, the claim against McDonalds cannot survive summary

judgment. The assignment of error is overruled as to McDonalds.

B. The Court Erred in Granting Proline’s Motion for Summary

Judgment

1. The open-and-obvious doctrine does not apply to independent contractors

{¶26} Oliver argued that the court erred in extending the open-and-obvious

doctrine to Proline because it is an independent contractor. She is correct.

{¶27} The open-and-obvious doctrine states that “an owner or occupier of

property owes no duty to warn invitees entering the property of open and obvious

dangers on the property.” Simmers v. Bentley Constr. Co., 64 Ohio St.3d 642, 644

(1992). The doctrine, however, applies only to the scope of a landowner’s duty. The

doctrine “arose out of premises liability law and extends only to those with the

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OHIO FIRST DISTRICT COURT OF APPEALS

requisite property interest in the premises.” Eschmann v. RLA Invests., Inc., 2016-Ohio-3331, ¶ 5 (1st Dist.), citing Simmers at 645. It governs “a landowner’s duty to

persons entering the property -- property over which the landowner has the right and

power to admit or exclude persons as invitees, licensees, or trespassers.” Simmers at

645. It does not provide freestanding defense to independent contractors. “An

independent contractor who creates a dangerous condition on real property is not

relieved of liability under the doctrine which exonerates an owner or occupier of land

from the duty to warn those entering the property concerning open and obvious

dangers on the property.” (Emphasis added.) Id. In the case of an independent

contractor, the ordinary laws of negligence must be looked at to determine the

contractor’s duty of care. Id.

{¶28} In this case, it is undisputed that Proline did not own the property where

the fall occurred but was only an independent contractor. As a result, the open-andobvious doctrine does not shield Proline from liability.

2. Appellant’s expert’s opinion is sufficient to create a material question of fact and

defeat summary judgment

{¶29} To survive summary judgment, Oliver needed to present evidence to

create a material question of fact with respect to each of the elements of her claim

against Proline. Mid-Century Ins. Co. v. Stites, 2021-Ohio-3839, ¶ 16 (1st Dist.)

(holding that to survive summary judgment, a plaintiff must produce affirmative, nonspeculative evidence supporting the elements of duty, breach, and proximate

causation). Specifically, because Oliver brought a negligence claim against Proline, she

needed to present admissible evidence that Proline breached the applicable standard

of care, and that that breach caused her injuries. Id. Oliver argues that the opinions

provided by her expert through his deposition, report, and testimony at the Daubert

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hearing created material questions of fact that defeated a motion for summary

judgment. We agree.

{¶30} The parties dispute whether Collette’s opinions were stricken by the

trial court. Considering the trial court’s lack of an order expressly striking or excluding

Collette’s reports or opinions following the Daubert hearing, they remained part of the

record. “Basic to the operation of the judicial system is the principle that a court speaks

through its judgments and orders.” Bell v. Thompson, 545 U.S. 794, 805 (2005),

quoting Murdaugh Volkswagen, Inc. v. First Natl. Bank, 741 F.2d 41, 44, (4th Cir.

1984). In fact, in its entry granting summary judgment, the trial court assumed

arguendo that the expert report was admissible for purposes of ruling on the motion,

went on to examine the opinions of Oliver’s expert and concluded that his opinions

were insufficient to create a material question of fact with respect to Proline’s liability.

{¶31} The trial court’s criticism of Collette’s opinions goes to the weight and

credibility of his testimony, questions that should be left to the trier of fact and are not

proper considerations for the court at the summary-judgment stage. Pitts v. Children's

Hosp. Med. Ctr., 2002-Ohio-2039, ¶ 9 (1st Dist.) (opining that the credibility of

experts’ conclusions and the relative weight expert opinion should enjoy are

determinations left to the trier of fact). Instead, in evaluating whether a motion for

summary judgment should be granted, the trial court must view all the evidence in the

light most favorable to the nonmoving party, which in this case is Oliver.

{¶32} Here, Collette opined that the ground being “unreasonably painted”

with “traffic marking paint that can become slippery when wet” “over a large area”

“contrary to the product’s safety precaution information” “without any secondary

product to increase slip resistance” was a dangerous condition caused by Proline’s

negligence and was “more likely than not the cause of Oliver’s incident and injuries.”

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{¶33} If believed, as it must be at the summary-judgment stage, Collette’s

opinion was sufficient to create a material question of fact and allow Oliver’s claim

against Proline to proceed to trial.

{¶34} Thus, we sustain Oliver’s assignment of error as it relates to the court’s

grant of summary judgment for Proline and remand the cause to the trial court.

III. Conclusion

{¶35} Therefore, the trial court’s grant of summary judgment in favor of

McDonalds is affirmed and the trial court’s grant of summary judgment in favor of

Proline is reversed, and the cause is remanded to the trial court for further proceedings

consistent with this opinion and the law.

Judgment affirmed in part, reversed in part, and cause remanded.

KINSLEY, P.J., and CROUSE, J., concur.

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