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Holcomb v. Hall

2026-08-28

Summary

Holding. The trial court erred in dismissing Holcomb's breach of contract claim for lack of subject matter jurisdiction, because the record establishes that Holcomb sought damages under the $15,000 jurisdictional limit of the municipal court. The judgment is reversed and remanded for further proceedings consistent with the opinion.

Norman Holcomb Jr. owned a property leased to Jinnifer Hall and Luther Draper. After they failed to pay rent, Holcomb filed suit seeking eviction and monetary damages for unpaid rent, late fees, utilities, repairs, and legal costs. The magistrate recommended a judgment of $9,929 plus interest and costs, which was less than Holcomb's requested $12,973.31. However, the trial court then dismissed the monetary damages claim, concluding it lacked jurisdiction because it believed Holcomb had sought more than $15,000, the maximum jurisdictional limit for municipal courts.

Holcomb appealed, arguing he never sought damages exceeding $15,000. The appellate court reviewed the record and found no evidence supporting the trial court's conclusion. Holcomb's original complaint capped his request at $15,000, his motion for default judgment sought $12,973.31, and the magistrate's recommended award was $9,929. The appellate court determined the trial court had subject matter jurisdiction over the breach of contract claim and that dismissing it was erroneous.

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

Key issues

  • Whether a municipal court has subject matter jurisdiction over a breach of contract claim when the plaintiff's requested damages are within the $15,000 statutory limit
  • Standard of appellate review for trial court jurisdictional determinations
  • Interpretation of damages sought based on complaint, motion filings, and magistrate's decision

Procedural posture

Holcomb appealed from the municipal court's dismissal of his breach of contract claim for lack of subject matter jurisdiction, following the magistrate's recommendation of a $9,929 judgment award.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

[Cite as Holcomb v. Hall, 2026-Ohio-3361.]

IN THE COURT OF APPEALS OF OHIO

SECOND APPELLATE DISTRICT

GREENE COUNTY

NORMAN HOLCOMB JR. :

: C.A. No. 2026-CA-7

Appellant :

: Trial Court Case No. CVG2500921

v. :

: (Civil Appeal from Municipal Court)

JINNIFER HALL :

LUTHER DRAPER : FINAL JUDGMENT ENTRY &

: OPINION

Appellees :

Pursuant to the opinion of this court rendered on August 28, 2026, the judgment of

the trial court is reversed, and the matter is remanded for further proceedings consistent with

the opinion.

Costs to be paid as stated in App.R. 24.

Pursuant to Ohio App.R. 30(A), the clerk of the court of appeals shall immediately

send a copy of the court’s ruling to each party and note that action on the docket.

Additionally, pursuant to App.R. 27, the clerk of the court of appeals shall send a certified

copy of this judgment, which constitutes a mandate, to the clerk of the trial court and note

the service on the appellate docket.

For the court,

RONALD C. LEWIS, PRESIDING JUDGE

HUFFMAN, J., and HANSEMAN, J., concur.

OPINION

GREENE C.A. No. 2026-CA-7

JENNIFER S. BOCK, Attorney for Appellant

JOHN C. MEEHLING, Attorney for Appellees

LEWIS, P.J.

{¶ 1} Plaintiff-appellant Norman Holcomb, Jr., appeals from the Fairborn Municipal

Court’s judgment dismissing his breach of contract claim against defendants-appellees

Jinnifer Hall and Luther Draper. For the following reasons, we reverse the judgment of the

trial court and remand the cause for further proceedings consistent with this opinion.

I. Course of Proceedings

{¶ 2} On May 29, 2025, Holcomb filed a complaint for forcible entry and detainer and

breach of contract in the Fairborn Municipal Court against Hall and Draper. According to

the complaint, Holcomb was the owner of a property on Powell Street in Fairborn where Hall

and Draper occupied the premises pursuant to a written lease agreement. Holcomb alleged

that Hall and Draper were served with a May 20, 2025 written notice to vacate the premises

for nonpayment of rent. Holcomb sought judgment against Hall and Draper for restitution

and recovery of the premises and a monetary judgment “not to exceed $15,000.” A forcible

entry and detainer hearing was scheduled for June 25, 2025.

{¶ 3} Hall and Draper did not file an answer to the complaint, but their attorney filed

a notice of appearance and request for a continuance of the forcible entry and detainer

hearing. The court granted the request and rescheduled the hearing for July 2, 2025.

Following a hearing on that date, the magistrate found that Holcomb was the landlord of the

premises, proper notice to vacate was served, and Hall and Draper were in default for nonpayment of rent. The magistrate recommended that Holcomb should regain possession of

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the premises forthwith and recover the cost of the suit and that the breach of contract claim

requesting monetary damages should be continued. The trial court adopted the

magistrate’s recommendation, granted Holcomb restitution of the premises, and continued

the breach of contract claim.

{¶ 4} On October 2, 2025, Holcomb filed a motion for a default judgment due to

defendants’ failure to plead or otherwise defend the action. Holcomb requested a judgment

“in the sum totaling Twelve Thousand Nine Hundred and Seventy-Three Dollars and 31/100

($12,973.31) statutory interest at 8% and court costs.” Holcomb attached to his motion his

“Tenant Statement,” listing the amounts that comprised the $12,973.31. He also attached

his affidavit identifying the following charges that Hall and Draper owed him under the lease:

$11,200 for rent and late fees from September 2024 through July 2025; $429 for a dumpster

for trash removal; $345.38 for cleaning and repairs above normal wear and tear; $318.93

for an unpaid water bill; and $1,980 for legal costs. These charges total $14,273.31. But

Holcomb deducted a $1,300 security deposit from the amount due, which resulted in the

requested sum of $12,973.31.

{¶ 5} Following a hearing on Holcomb’s motion for default judgment, the magistrate

issued a December 4, 2025 decision recommending a $9,929 judgment against Hall and

Draper together with interest at the rate of 8% per annum from the date of judgment, plus

costs. The magistrate recommended reducing a portion of the damages Holcomb

requested, which resulted in the $9,929 recommended award rather than Holcomb’s

requested amount of $12,937.31. No objections were filed to the magistrate’s decision.

{¶ 6} On December 26, 2025, the trial court issued a judgment entry stating that

“there is an error of law or other defect on the face” of the magistrate’s decision. According

to the trial court, the magistrate’s decision reflected that “the Plaintiff submitted evidence at

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the trial in support of an amount sought in excess of $15,000, which is this Court’s

jurisdictional limit. As Plaintiff sought an amount at trial in excess of this Court’s jurisdiction,

the Court no longer has jurisdiction on the Second Claim.” Therefore, the trial court

dismissed Holcomb’s breach of contract claim “for lack of jurisdiction.”

{¶ 7} Holcomb filed an objection to the trial court’s decision arguing that he never

sought more than $15,000 in damages. The trial court issued a January 2, 2026 order

finding that there was no mechanism to object to a judgment and stating that the appropriate

remedy was to file an appeal within 30 days of the judgment entry. The court also noted

that it did not have the benefit of having a transcript of the proceedings before the magistrate.

The court then stated:

The Court interprets the December 4, 2025, Magistrate’s Decision to reflect

that Plaintiff at the hearing sought rent in the amount of $1,300 per month for

the months of December, 2024, through April, 2025; the amount of rent in the

amount of $1,400 per month for the months of May, 2025, through July, 2025;

the amount of late fees in the amount of $50 per month for the months of

December, 2024, through July, 2025; the amount of late fees of $10 per day

for every day from December 1, 2024, through July, 2025; the amount of $429

for trash removal; the amount of $309.70 for water bills; and the amount of

$1,300 for attorney fees as part of damages, plus an unknown amount for

excessive wear and tear beyond ordinary wear and tear. Therefore, the Court

overrules the Objection to Judge’s Decision.

{¶ 8} Holcomb filed a timely notice of appeal from the trial court’s December 26, 2025

judgment.

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II. The Trial Court Erred in Finding that It Did Not Have Jurisdiction Over

Holcomb’s Breach of Contract Claim

{¶ 9} Holcomb’s assignment of error states:

The trial court erred by dismissing the Second Claim for lack of jurisdiction in

Case No. CVG 2500921 in Fairborn Municipal Court.

{¶ 10} The trial court dismissed Holcomb’s claim for monetary damages based on its

finding that Holcomb sought damages exceeding the jurisdictional limit of the municipal

court. In essence, the trial court dismissed Holcomb’s claim for monetary damages due to

a lack of subject matter jurisdiction. “An appellate court conducts a de novo review of a trial

court's determination regarding the existence of subject matter jurisdiction, whether the trial

court has or lacks jurisdiction in the first place, because such determination is a matter of

law.” Baker v. Baker, 2018-Ohio-3065, ¶ 34 (2d Dist.), citing Mulatu v. Girsha, 2011-Ohio6226, ¶ 26 (12th Dist.).

{¶ 11} R.C. 1901.17 provides, in pertinent part, that “[a] municipal court shall have

original jurisdiction only in those cases in which the amount claimed by any party, or the

appraised value of the personal property sought to be recovered, does not exceed fifteen

thousand dollars . . . .” R.C. 1901.17 also provides, “Judgment may be rendered in excess

of the jurisdictional amount, when the excess consists of interest, damages for the detention

of personal property, or costs accrued after the commencement of the action.” The Ohio

Supreme Court has held that a municipal court has no jurisdiction under R.C. 1901.17 to

decide the merits of a case when the plaintiff seeks an amount of monetary damages that

exceeds the $15,000 limit. See State ex rel. Natl. Emp. Benefit Servs., Inc. v. Court of

Common Pleas of Cuyahoga Cty., 49 Ohio St.3d 49, 50 (1990).

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{¶ 12} In its December 26, 2025 judgment, the trial court found that there was “an

error of law or other defect on the face” of the magistrate’s decision. According to the trial

court, the magistrate’s decision reflected that Holcomb submitted evidence at the hearing

“in support of an amount sought exceeding $15,000.” The trial court did not explain in its

judgment entry how it arrived at its conclusion that Holcomb had sought more than $15,000

in damages. However, in its January 2, 2026 order, the trial court provided some insight

into its thinking by stating how it interpreted the damage amounts referenced in the

magistrate’s decision. We have reviewed the record and must conclude that the trial court

erred in finding that Holcomb sought more than $15,000 in monetary damages.

{¶ 13} In his complaint, Holcomb sought a monetary judgment “not to exceed

$15,000.” In his motion for default judgment, Holcomb requested a judgment for

$12,973.31 plus statutory interest at 8% and court costs. Holcomb attached to his motion

his “Tenant Statement,” listing the amounts that comprised the $12,973.31. He also

attached his affidavit identifying the charges that Hall and Draper owed him pursuant to the

lease. Those charges totaled $12,973.31 after Holcomb deducted a $1,300 security

deposit from the amount due. This total included all the late fees sought by Holcomb. After

the hearing, the magistrate recommended an award of only $9,929 plus interest at the rate

of 8% per annum from the date of judgment, plus costs. The magistrate’s decision identified

the categories and amounts of damages sought by Holcomb and explained why some of the

requested damages should not be awarded. The magistrate’s decision did not identify any

new damages Holcomb sought beyond the $12,973.31 he had requested in his motion for

default judgment. In sum, the face of the magistrate’s decision establishes that Holcomb

sought $12,973.31 in damages but was entitled to only $9,929 in damages.

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{¶ 14} Nothing on the face of the magistrate’s decision or in the record before us

supports the trial court’s decision to dismiss Holcomb’s claim for monetary damages due to

a lack of subject matter jurisdiction. Rather, the face of the magistrate’s decision and the

record before us establish that Holcomb sought under $15,000 in damages and the

magistrate recommended an award of less than $15,000 in damages. Therefore, the trial

court had subject matter jurisdiction over Holcomb’s claim for monetary damages and erred

when it dismissed Holcomb’s breach of contract claim.

{¶ 15} The assignment of error is sustained.

III. Conclusion

{¶ 16} Having sustained the assignment of error, we reverse the judgment of the trial

court and remand the cause for further proceedings consistent with this opinion.

HUFFMAN, J., and HANSEMAN, J., concur.

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