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Zurieck v. Durrani

2026-08-28

Summary

Holding. The trial court's judgments are affirmed in part and reversed in part. The court sustained only the defendants' argument regarding set-off entitlement and remanded for the trial court to determine the proper set-off amount based on plaintiffs' settlements with other defendants; all other assignments of error were overruled and the trial court's judgments were affirmed.

Two patients sued Dr. Abubakar Atiq Durrani and his spine surgery practice for negligence, lack of informed consent, and fraud related to surgical procedures. Mary Zurieck underwent spinal fusion surgery that allegedly failed to address her pain and led to additional surgeries for unrelated conditions. Samantha Hamilton had fusion surgery as a teenager that allegedly caused serious postoperative complications, including infection and a protruding rod requiring multiple additional surgeries, causing ongoing pain and limiting her career and daily activities. Both plaintiffs claimed Dr. Durrani provided inadequate informed consent and failed to offer conservative treatment alternatives before recommending surgery.

The jury found in favor of both plaintiffs on negligence, lack of informed consent, and fraudulent misrepresentation claims, but ruled against them on battery claims. The trial court applied statutory caps to noneconomic damages and awarded prejudgment interest, finding the plaintiffs made good-faith settlement demands while the defendant did not. On appeal, the appellate court examined several procedural and evidentiary issues raised by the defendants, including whether the statute of repose barred one plaintiff's claims and whether consolidating the two separate trials was proper.

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

Key issues

  • Whether the statute of repose barred the plaintiff's claims despite the absent-defendant tolling statute and 2024 legislative amendment
  • Whether improper consolidation of two separate medical-malpractice cases constituted harmless error
  • Whether the absent-defendant jury instruction permitting an adverse inference was proper
  • Whether expert medical testimony exceeded the scope of the witness's qualifications
  • Whether defendants were entitled to set-off based on plaintiffs' settlements with other tortfeasors

Procedural posture

Two patients appealed adverse trial court rulings in their medical-malpractice cases against the same spine surgeon; the appellate court consolidated the appeals and considered the defendants' five assignments of error challenging the trial outcomes and various evidentiary and procedural rulings.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

[Cite as Zurieck v. Durrani, 2026-Ohio-3369.]

IN THE COURT OF APPEALS

FIRST APPELLATE DISTRICT OF OHIO

HAMILTON COUNTY, OHIO

MARY ZURIECK, : APPEAL NO. C-250170

TRIAL NO. A-1400581

Plaintiff-Appellee, :

vs. :

ABUBAKAR ATIQ DURRANI, M.D., :

and :

CENTER FOR ADVANCED SPINE :

TECHNOLOGIES, INC.,

:

Defendants-Appellants,

:

and

:

JOURNEY LITE OF CINCINNATI, LLC,

:

Defendant.

:

SAMANTHA HAMILTON, : APPEAL NO. C-250173

TRIAL NO. A-1706393

Plaintiff-Appellee, :

vs. :

JUDGMENT ENTRY

ABUBAKAR ATIQ DURRANI, M.D., :

and :

CENTER FOR ADVANCED SPINE :

TECHNOLOGIES, INC.,

:

Defendants-Appellants,

:

and

:

CINCINNATI CHILDREN’S HOSPITAL

MEDICAL CENTER, :

WEST CHESTER HOSPITAL, LLC, :

and :

UC HEALTH, :

Defendants. :

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

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

Further, the court holds that there were reasonable grounds for these appeals, allows no penalty, and orders that costs be taxed 50% to appellants and 50% to appellees.

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.

To the clerk:

Enter upon the journal of the court on 8/28/2026.

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

IN THE COURT OF APPEALS

FIRST APPELLATE DISTRICT OF OHIO

HAMILTON COUNTY, OHIO

MARY ZURIECK, : APPEAL NO. C-250170

TRIAL NO. A-1400581

Plaintiff-Appellee, :

vs. :

ABUBAKAR ATIQ DURRANI, M.D., :

and :

CENTER FOR ADVANCED SPINE :

TECHNOLOGIES, INC.,

:

Defendants-Appellants,

:

and

:

JOURNEY LITE OF CINCINNATI, LLC,

:

Defendant.

:

SAMANTHA HAMILTON, : APPEAL NO. C-250173

TRIAL NO. A-1706393

Plaintiff-Appellee, :

vs. :

OPINION

ABUBAKAR ATIQ DURRANI, M.D., :

and :

CENTER FOR ADVANCED SPINE :

TECHNOLOGIES, INC.,

:

Defendants-Appellants,

:

and

:

:

CINCINNATI CHILDREN’S HOSPITAL

MEDICAL CENTER, :

WEST CHESTER HOSPITAL, LLC, :

and :

UC HEALTH, :

Defendants. :

Civil Appeals From: Hamilton County Court of Common Pleas

Judgments Appealed From Are: Affirmed in Part, Reversed in Part, and Cause

Remanded

Date of Judgment Entry on Appeal: August 28, 2026

Statman Harris, LLC, Alan J. Statman and Benjamin A. Maraan, II, for PlaintiffsAppellees,

Taft Stettinius & Hollister LLP, Philip D. Williamson, Aaron M. Herzig, Russell S. Sayre, and Annie M. McClellan, for Defendants-Appellants.

OHIO FIRST DISTRICT COURT OF APPEALS

MOORE, Judge.

{¶1} Defendants-appellants Dr. Abubakar Atiq Durrani and the Center for

Advanced Spine Technologies, Inc., (“CAST”) (collectively, “Durrani”), appeal the

judgments of the Hamilton County Court of Common Pleas in favor of plaintiffsappellees Mary Zurieck and Samantha Hamilton (“plaintiffs”). At the conclusion of the

trial, the jury found in favor of plaintiffs on their claims for negligence, lack of

informed consent, and fraudulent misrepresentation. The jury returned verdicts in

Durrani’s favor on the battery claims.1

{¶2} Durrani now raises five assignments of error. First, as to Hamilton only,

Durrani alleges that the trial court should have granted their motion for judgment on

the pleadings because the statute of repose barred Hamilton’s claims. Second, Durrani

argues that the trial court erred when it denied their combined motion for a judgment

notwithstanding the verdict (“JNOV”) or, in the alternative, a new trial, and asserts

that the trial court committed several evidentiary errors. Durrani asserts that (1) the

trial court erred when it joined plaintiffs’ cases for trial; (2) the court improperly

instructed the jury on Dr. Durrani’s absence; and (3) these errors were not harmless.

Third, Durrani argues that Dr. Saini’s testimony was improper under Evid.R. 702 and

this court’s precedent in Stephenson v. Durrani, 2023-Ohio-2500, ¶ 71-73 (1st Dist.).

Fourth, Durrani contends that they were entitled to a set-off based on plaintiffs’

settlements with other tortfeasors. Fifth, Durrani argues that the court erred in

awarding prejudgment interest to plaintiffs.

{¶3} We hold that only Durrani’s argument regarding set-off is meritorious.

We, therefore, sustain Durrani’s fourth assignment of error and remand the cause to

1 We sua sponte consolidate these separate appeals into a single opinion and judgment.

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OHIO FIRST DISTRICT COURT OF APPEALS

the trial court to determine the amount of set-off that Durrani is entitled to. We

overrule the remaining assignments of error and affirm the trial court’s judgments in

all other respects.

I. Facts and Procedure

A. The Complaints

{¶4} Zurieck filed her complaint on January 31, 2014, alleging negligence,

battery, lack of informed consent, intentional infliction of emotional distress, fraud,

and spoliation of evidence against Durrani.

{¶5} Hamilton initially filed her complaint in July 2014 in the Butler County

Court of Common Pleas. Hamilton voluntarily dismissed this complaint in November

2015 and refiled it in the Hamilton County Court of Common Pleas as a part of a multiplaintiff case on August 15, 2016. The court severed those cases and ordered each

plaintiff to file an amended complaint, which Hamilton filed on December 7, 2017.

Plaintiffs alleged the same claims in their respective complaints.

B. Durrani’s Motion for Judgment on the Pleadings

{¶6} Durrani moved for judgment on the pleadings in Hamilton’s case,

arguing that the statute of repose barred Hamilton’s claims. Durrani based their

argument on the General Assembly’s October 2024 amendment to R.C. 2305.15, the

absent-defendant tolling statute. Durrani argued that Hamilton’s claims were barred

because she brought them more than four years after she reached the age of majority.

Durrani asserted that the amendment expressly states that the absent-defendant

tolling statute does not toll the medical-claim statute of repose, and because Hamilton

did not timely file her claim, it was barred.

{¶7} Hamilton responded that R.C. 2305.15 tolled the statute of repose when

Dr. Durrani absconded, and that the one-year savings statute in R.C. 2305.19 allowed

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OHIO FIRST DISTRICT COURT OF APPEALS

her claim to survive beyond the expiration of the statute of repose. The matter

proceeded to trial.

C. The Trial

1. Plaintiffs’ Testimony

{¶8} At trial, both plaintiffs asserted that Dr. Durrani failed to provide

adequate informed consent, to perform proper examinations, and to offer conservative

treatment alternatives before recommending surgical interventions.

a. Mary Zurieck’s Testimony

{¶9} Zurieck had initially undergone surgery in 2007 by an orthopedic

surgeon and in 2009 by a spine surgeon. Zurieck stated that, although she had low

back pain, she sought treatment from both surgeons to address the pain in her left leg.

Zurieck explained that the spine surgeon, to whom her orthopedic surgeon referred

her, resolved her leg pain. When Zurieck’s back pain returned, and she was unable to

be treated by that surgeon again, she scheduled a visit with Dr. Durrani.

{¶10} Zurieck testified that her initial visit with Dr. Durrani lasted ten

minutes, during which he told her that he could “fix” her with two surgeries. By

Zurieck’s second appointment with Dr. Durrani at CAST—the presurgical

appointment—Zurieck complained of pain in her right knee and in her right groin. She

was using a cane on her own volition due to concern that her knee would give out and

cause her to fall while walking. Zurieck refuted documentation by Dr. Durrani stating

that she had pain “shooting down [her] right and left leg,” and reiterated that the pain

was in her right knee rather than down her leg. She also denied telling Dr. Durrani that

she felt numbness on her left side or that her pain limited her ability to do yardwork.

{¶11} Zurieck testified that, although she had undergone presurgical

conservative treatment under the care of her previous surgeons, Dr. Durrani

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OHIO FIRST DISTRICT COURT OF APPEALS

recommended surgery during the initial ten-minute visit but presented no nonsurgical

alternatives. Zurieck’s consent for surgery showed that she was to undergo a

laminectomy and an extension of spinal fusion from L1-L2, and she testified that she

did not know that a laparoscopic procedure would also be done.

{¶12} Zurieck recalled feeling such “excruciating” back pain when she woke

up from surgery that she could not gauge the level of pain in her groin and knee. She

could tell after a few weeks that her back, groin, and knee pain were the same as before

Dr. Durrani’s surgery. Zurieck reported her concerns to Dr. Durrani, but she never

went back for the second surgery due to CAST ceasing operations.

{¶13} After Dr. Durrani’s surgery, Zurieck saw another orthopedic surgeon,

who recommended that she see a spine surgeon. That spine surgeon, in turn,

recommended that she return to the orthopedic surgeon. The orthopedic surgeon

identified the source of Zurieck’s hip pain and performed a total hip replacement. The

hip surgery relieved her knee pain, but the groin pain persisted. The orthopedic

surgeon then referred Zurieck to a general surgeon, who identified a herniated groin

as the source of her groin pain, which was rectified after she underwent hernia surgery.

{¶14} Zurieck’s back pain, however, had gotten worse. At the time of trial, she

had been treating her pain with Tramadol as prescribed by her family doctor for “some

number of years.”

b. Regina and Samantha Hamilton’s Testimony

{¶15} Hamilton’s mother, Regina Hamilton, testified that Hamilton’s

pediatrician referred her to Cincinnati Children’s Hospital Medical Center

(“CCHMC”), where Dr. Charles Mehlman diagnosed her with S-shaped scoliosis with

curves in both lumbar and thoracic spines. Hamilton was about 13 years old at that

time. Dr. Durrani, who was then employed with CCHMC, performed surgical bracing

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OHIO FIRST DISTRICT COURT OF APPEALS

on Hamilton’s spine. Regina testified that the procedure was successful.

{¶16} Regina was notified that Dr. Durrani was starting his own practice,

CAST. During Hamilton’s first visit with Dr. Durrani at CAST, Dr. Durrani told her

that her upper curve had progressed significantly, and this would affect her heart and

lungs without immediate surgery. Dr. Durrani recommended a fusion, which entailed

inserting rods on both sides of her spine. She was 16 years old at that time.

{¶17} Regina recalled that the fusion took longer than expected, and Hamilton

was taken to the ICU after the fusion to address breathing issues and to get her pain

under control. Hamilton was discharged three or four days later, but she was still in “a

lot of pain.” One of the rods that Dr. Durrani placed could be felt and seen through

Hamilton’s skin at the top of her spine. The protruding rod kept Hamilton from

continuing postsurgical physical therapy. Hamilton developed a severe rash covering

her chest and back, and an oozing, green pus infection at her incision persisted for

months. Regina testified she applied the silver nitrate that Dr. Durrani prescribed for

the infection as directed.

{¶18} These complications required three more procedures to address

Hamilton’s infection. During the fourth surgery, Dr. Durrani removed the protruding

rod. In the fifth surgery, Dr. Durrani replaced some screws and again addressed the

pus oozing from the surgical site. Regina testified that Hamilton has had pain since

the rods were inserted and continues to experience postsurgical problems.

{¶19} Hamilton testified that, before her first surgery at CAST, Dr. Durrani

told her that her heart and lungs would be affected by her scoliosis if she did not have

surgery, and that he assured her that the surgery would be “easy.” She recalled having

“terrible pain” and other postoperative symptoms. These complications caused issues

with her later pregnancy and delivery, including a difficult epidural placement and an

9

OHIO FIRST DISTRICT COURT OF APPEALS

emergency C-section. She added that her left arm goes numb while feeding her baby.

Hamilton stated that she had seen several other doctors after Dr. Durrani’s procedure

but eventually stopped seeing additional providers.

{¶20} Hamilton testified that she had to change her career path from nursing

to business management due to her ongoing back issues. She currently works as a

training manager in vertical farming, where she can avoid roles with physical

demands. She testified that she takes hydrocodone and over-the-counter medications

as needed for pain. She explained that, since the surgeries, she (1) cannot lift laundry

baskets or perform household chores, (2) avoids activities like canoeing, kayaking, and

riding roller coasters, and (3) has difficulty caring for her six-month-old daughter,

including bathing and playing on the floor with her. Her husband assists her with

household tasks and childcare.

{¶21} Both plaintiffs offered expert testimony as to whether Dr. Durrani

deviated from the standard of care in treating them.

2. The Absent-Defendant Instruction

{¶22} The trial court instructed the jury as to Dr. Durrani’s absence from trial:

The Defendant Dr. Durrani has not attended these proceedings

in person. He is represented here by counsel. You shall not speculate on

why he is not present or consider his absence for any purpose, except as

instructed below. Dr. Durrani has voluntarily left the jurisdiction,

removing himself from Plaintiffs’ ability to subpoena him to trial. When

a party such as Dr. Durrani has relevant evidence or testimony within

his or her control and the party fail[s] to produce that relevant evidence

or testimony, that failure gives rise to an inference that the evidence or

testimony is unfavorable to that party.

10

OHIO FIRST DISTRICT COURT OF APPEALS

D. The Jury’s Verdict

{¶23} The jury found for both plaintiffs on their claims for negligence, lack of

informed consent, and fraudulent misrepresentation. The jury found in favor of

Durrani on the battery claims. The jury awarded damages as follows:

Plaintiff Compensatory Past Past Pain Future Pain Past Loss of Future Loss Punitive

Damages Medical and and Enjoyment of Damages

Expenses Suffering Suffering of Life Enjoyment and

of Life Attorney

Fees

Hamilton $1,601,500 $1,500 $400,000 $400,000 $400,000 $400,000 $337,500 Zurieck $289,000 $1,000 $72,000 $72,000 $72,000 $72,000 $337,500

E. Posttrial Motions

1. Motion for a Judgment Notwithstanding the Verdict, a New Trial, and/or

Remittitur

{¶24} Durrani moved for a judgment notwithstanding the verdict (“JNOV”), a

new trial, and/or remittitur. Pertinent to this appeal, Durrani asserted the absentdefendant instruction gave rise to a negative inference, and that joinder was improper,

and they requested a set-off against plaintiffs’ settlements with other tortfeasors and

remittitur to “mold” the noneconomic damages to the statutory limits.

{¶25} The trial court granted remittitur but otherwise denied Durrani’s

motions. The trial court applied the statutory-damage caps, reducing Hamilton’s

noneconomic damages award to $500,000, making the total compensatory award

$501,500. The trial court reduced Zurieck’s noneconomic damages award to

$250,000, making the total compensatory award $251,000. As the jury found that

both plaintiffs were entitled to attorney’s fees, the parties stipulated that each plaintiff

should receive $37,500.

2. Plaintiffs’ Motions for Prejudgment Interest

{¶26} Plaintiffs moved for prejudgment interest. The conclusion of the

hearing on plaintiffs’ motions brought out the same facts as in other Durrani cases:

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OHIO FIRST DISTRICT COURT OF APPEALS

plaintiffs made a $500,000 settlement demand and counsel for Durrani informed the

court Durrani offered $4,000,000 to all remaining Durrani plaintiffs, and they were

not interested in making individual offers. The trial court made similar findings in this

matter to those in other Durrani cases, noting that the global offer would leave

plaintiffs with less in damages than was awarded by the jury. The court, finding that

plaintiffs made good-faith settlement demands while Duranni failed to make goodfaith efforts to settle the cases, granted plaintiffs’ motions for prejudgment interest.

{¶27} This appeal followed.

II. Analysis

A. Durrani’s Motion for Judgment on the Pleadings Was Properly

Denied

{¶28} In their first assignment of error, Durrani argues that the trial court

erred by denying their motion for judgment on the pleadings. Dismissal on a Civ.R.

12(C) motion for judgment on the pleadings is proper when a court construes as true

the material allegations in the complaint, along with drawing all reasonable inferences

in favor of the nonmoving party and finds beyond doubt that the plaintiff can prove no

set of facts that would entitle the plaintiff to relief. Georgantonis v. City of Reading,

2020-Ohio-3961, ¶ 8 (1st Dist.); Planned Parenthood S.W. Ohio Region v. Ohio Dept.

of Health, 2026-Ohio-639, ¶ 25-26 (1st Dist.). We review a trial court’s ruling on a

Civ.R. 12(C) motion for a judgment on the pleadings de novo. Id.

1. Statute of Repose

{¶29} R.C. 2305.113(C), Ohio’s statute of repose for medical claims, provides,

with specified exceptions, that “No action upon a medical . . . claim shall be

commenced more than four years after the occurrence of the act or omission

constituting the alleged basis of the medical . . . claim.” Wilson v. Durrani, 2020-Ohio12

OHIO FIRST DISTRICT COURT OF APPEALS

6827, ¶ 15. R.C. 2305.113(C) “exists to give medical providers certainty with respect to

the time within which a claim can be brought and a time after which they may be free

from the fear of litigation.” Id. at ¶ 16, quoting Ruther v. Kaiser, 2012-Ohio-5686, ¶

19. It is a “true statute of repose that applies to both vested and nonvested claims.” Id.,

quoting Antoon v. Cleveland Clinic Found., 2016-Ohio-7432, ¶ 1. “Therefore, any

medical-malpractice action must be filed within four years of the occurrence of the act

or omission alleged to have caused a plaintiff’s injury.” Id. R.C. 2305.113(C) provides

an exception for those who are minors at the time of the act or omission, giving them

four years after they reach the age of majority to file their claim.2

{¶30} Durrani argues Hamilton commenced her action in August 2016, which

was more than four years after her 18th birthday. Based on the Ohio Supreme Court’s

holding in Wilson, Durrani asserts that Hamilton’s claims are barred under the terms

of the statute of repose.

2. The Absent-Defendant Saving Provision Tolled Hamilton’s Claims

{¶31} Hamilton argues that her claims are not barred by the statue of repose—

R.C. 2305.113(C)—because they were tolled under the absent-defendant statute. This

argument has merit. In Elliot v. Durrani, 2022-Ohio-4190, ¶ 24-25, the Ohio Supreme

Court held that the absent-defendant saving provision under R.C. 2305.15(A) tolled

the medical statute of repose. Thereafter, the 135th General Assembly enacted House

Bill 179, which added R.C. 2305.15(A)(2)(b)3 “to explicitly overrule the decision of the

Ohio Supreme Court in the case of Elliot v. Durrani, 2022-Ohio-4190.” 2023 Am.

Sub.H.B. No. 179. R.C. 2305.15(A)(2)(b) explicitly provides that the section does not

2 The other exceptions set forth in R.C. 2305.113(D) include exceptions for those of “unsound mind”

and for persons who did not discover their injury within three years of the act or omission and filed their claim within the following year.

3 Durrani erroneously cites the amendment as R.C. 2305.15(B), which pertains to the absence of a

defendant due to imprisonment.

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OHIO FIRST DISTRICT COURT OF APPEALS

apply to R.C. 2305.113(C). However, because the General Assembly did not explicitly

make the amendment retroactive, and Hamilton’s 2016 complaint filed in Hamilton

County Court of Common Pleas was filed prior to the amendment, that complaint was

not barred.

{¶32} Hamilton’s fifth and final surgery was performed on March 10, 2011,

when she was 17 years old. The record shows that Hamilton reached the age of majority

on September 28, 2011. Therefore, under the statute of repose, Hamilton had four

years from September 28, 2011, or until September 29, 2015,4 to file her claim.

Accordingly, her August 2016 complaint was filed beyond the statute of repose.

Pursuant to Wilson, the complaint that she filed in Hamilton County does not relate

back to the date when she initially filed her Butler County claims for purposes of the

statute of repose. See Wilson, 2020-Ohio-6827, at ¶ 25.

{¶33} We must next turn to the 2024 amendment to R.C. 2305.15—the absentdefendant tolling statute—to determine whether the amended version applies to

Hamilton’s claims.

{¶34} We disagree with Durrani’s proposition that the amended R.C. 2305.15

was meant to be applied retroactively, and therefore, Hamilton’s claims remain

barred. First, under Section 1c, Article II, of the Ohio Constitution, no law or section

of any law “passed by the general assembly shall go into effect until ninety days after

it shall have been filed by the governor in the office of the secretary of state, except as

herein provided.” See Pelletier v. Mercy Health Youngstown, LLC, 2024-Ohio-3397,

¶ 12 (7th Dist.). The amended statute was enacted on July 24, 2024. 2023 Am.Sub.H.B.

No. 179. Second, “[a] statute is presumed to be prospective in its operation unless

expressly made retrospective.” See id.; R.C. 1.48. There is no language in H.B. 179 that

4 We take judicial notice that September 28, 2015, the actual four-year mark, fell on a Sunday.

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OHIO FIRST DISTRICT COURT OF APPEALS

expressly made its application retroactive. Accordingly, former R.C. 2305.15 saved

Hamilton’s claims from being barred by the statute of repose as her complaint was

filed before the 2024 amendment was enacted. The first assignment of error is

overruled.

B. Consolidation of Trials

{¶35} In their second assignment of error, Durrani challenges the trial court’s

joining of plaintiffs’ trials, arguing that the court erred in joining these cases for trial.

Based on our holding in Wilson v. Durrani, 2026-Ohio-2279, ¶ 51-52, 84 (1st Dist.),

Durrani is correct.5

{¶36} In Wilson, the majority examined the language in Civ.R. 42(A). It

concluded that the rule’s reference to “common question of law or fact” requires that

a party seeking to join cases must demonstrate that the cases present common

questions capable of being resolved with a single, common answer. Id. at ¶ 58, 77. The

majority explained that a common question of law concerns questions about the

defendant’s liability that are capable of uniform resolution across the consolidated

cases. Id. at ¶ 57. This is distinct from common questions of fact, which concern

overlapping material facts that are capable of uniform resolution at once. Id. at ¶ 68.

It is not enough that the cases contain common allegations, nor is it enough that there

are overlapping insignificant facts that do not bear on the disposition of the cases. Id.

at ¶ 68. Questions that require unique and individualized proof are not common in

nature. Id. at ¶ 76.

{¶37} Where the cases are not linked by common questions, then joinder is

5 While acknowledging my dissent in Wilson, the majority obviously did not adopt my reasoning.

Wilson is now the law of this court and therefore is followed for purposes of determining the instant appeal, my disagreement with that opinion notwithstanding. See Wilson at ¶ 95-125 (Moore, J., dissenting).

15

OHIO FIRST DISTRICT COURT OF APPEALS

improper, and we must then assess whether the court’s improper joinder constituted

harmless error. Id. at ¶ 84. Pursuant to Civ.R. 61 and R.C. 2309.59, courts must

disregard errors that do not affect a party’s substantial rights. “To find that substantial

justice has not been done, a court must find (1) errors and (2) that without those errors,

the jury probably would not have arrived at the same verdict.” Hayward v. Summa

Health Sys., 2014-Ohio-1913, ¶ 25. To determine the existence of prejudicial error, we

are “bound by the disclosures of the record.” Id.

{¶38} In this case, the court’s consolidation was improper under the analysis

adopted by the majority in Wilson. While the plaintiffs put forth common legal claims

for negligence, lack of informed consent, fraud, and battery, these claims were reliant

upon individualized facts and were incapable of uniform resolution. In Wilson, we

considered the same claims and held that those were incapable of uniform resolution.

Wilson, 2026-Ohio-2279, at ¶ 72 (1st Dist.). As to the negligence claims, whether

Durrani was liable hinged on individualized reviews of each plaintiff’s imaging to

determine whether they required surgery, as well as each plaintiff’s individualized

injury history to determine whether Durrani breached the standard of care and

whether plaintiffs sustained damages. Similarly, plaintiffs’ lack of informed consent,

battery, and fraud claims are not capable of uniform resolution and therefore should

not have been consolidated. Id. at ¶ 73. Because “no one piece of evidence could

answer” whether plaintiffs needed surgery, plaintiffs’ claims should not have been

consolidated. Id. at ¶ 76.

{¶39} In holding that the court erred in consolidating these cases, we next

consider whether the court’s decision constituted a harmless error. Id. at ¶ 84. Durrani

asserts that they had no burden to show that they were prejudiced by consolidation

because “plaintiffs never met their burden to justify consolidation in the first place.”

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OHIO FIRST DISTRICT COURT OF APPEALS

Based on Wilson, we disagree. See Wilson at ¶ 86 (“As the appellant, Durrani bears the

burden of demonstrating the improper joinder of the plaintiffs’ cases for trial was not

harmless . . . In analyzing harmless error, we accordingly confine our review to matters

that Durrani has brought to our attention on appeal.”). Unlike in Wilson, here, Durrani

failed to point to any specific evidence in the record to demonstrate prejudice as the

result of the improper joinder.

{¶40} Based on our independent review of the record, we cannot say that any

error rose beyond the harmless threshold. The verdicts, jury interrogatories, and

damage awards all support the conclusion that the jury was able to and did follow the

court’s instruction and treated each of these cases separately, reaching an independent

resolution for each case. See Boggs v. Durrani, 2026-Ohio-210, ¶ 121 (1st Dist.)

(“Where a thorough review of the record shows that the jury properly considered each

case separately and on its own merit, as instructed, the record does not indicate

prejudice from the joinder of trials under Civ.R. 42 that is inconsistent with substantial

justice. See, e.g., Courtney v. Durrani, 2025-Ohio-2335, ¶ 58 (1st Dist.); see also Jones

v. Durrani, 2024-Ohio-1776, ¶ 26 (1st Dist.).”); Civ.R. 61. Ultimately, the trial court

instructed the jury to consider each case on its own merit, and the jury found in favor

of Durrani and CAST on the plaintiffs’ claims for battery and returned different

compensatory damages awards in each joined action. Further, the jury verdicts were

not unanimous. This shows that the jury was able to successfully parse through the

evidence and reach independent conclusions as to each action joined. Accordingly, we

hold that no prejudice occurred in the trial court’s joining of plaintiffs’ cases for trial.

C. The Absent-Defendant Instruction

{¶41} Under their second assignment of error, Durrani also argues that the

trial court improperly instructed the jury on Dr. Durrani’s absence. A trial court’s

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OHIO FIRST DISTRICT COURT OF APPEALS

decision to grant or deny a proposed jury instruction is reviewed for an abuse of

discretion. Niehaus v. Durrani, 2023-Ohio-4818, ¶ 35 (1st Dist.). The absentdefendant instruction here mirrors the instruction submitted to the jury in Boggs at ¶

87-88, Clark v. Durrani, 2025-Ohio-3096, ¶ 20 (1st Dist.), and Ravenscraft v.

Durrani, 2025-Ohio-2900, ¶ 135-136 (1st Dist.). In those cases, this court held that

the instruction, as a whole, did not prejudice Durrani because it was apparent that the

inference was permissive, not required, and that it also “clearly set forth what evidence

should be considered by the jury in rendering its decision.” Id. at ¶ 38. We further held

that a thorough review of the entire proceeding revealed that the jury was not misled.

Id. at 39. As in the instant matter, we noted the jury found for Durrani on some claims.

Id. That, combined with jury interrogatories showing the jury relied on the actual

evidence in the record, demonstrated that the trial court’s instruction did not affect

the jury’s verdict. Id. We likewise hold the same here and decline Durrani’s invitation

to overturn the established precedent of this court. The second assignment of error is

overruled.

D. Dr. Saini’s Testimony

{¶42} Both plaintiffs and Durrani presented expert medical testimony from

multiple experts to support their positions. However, the only such testimony at issue

on appeal is with respect to the testimony of plaintiffs’ expert, Dr. Ranjiv Saini.

{¶43} Expert testimony is governed by Evid.R. 702. A witness may testify as

an expert when he is “qualified as an expert by specialized knowledge, skill,

experience, training, or education regarding the subject matter of the testimony.”

Evid.R. 702(B). In Ohio, a witness testifying in a medical-malpractice case need not

practice in the same specialty as that of the defendant-physician; rather, it is the scope

of the witness’s knowledge and not the artificial classification by title that should

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govern the threshold question of his qualifications. Adams v. Durrani, 2022-Ohio-60,

¶ 50 (1st Dist.), appeal not accepted, 2022-Ohio-1485, overruled on other grounds by

Fenner v. Durrani, 2025-Ohio-4477 (1st Dist.). So long as the expert witness

demonstrates knowledge of the standards of the specialty, and that knowledge enables

the witness to provide expert testimony involving whether the defendant’s conduct

conformed with that specialty’s particular standards, the witness is competent to

testify as an expert. Id.

{¶44} Dr. Saini is a teleradiologist, neuroradiologist, and board-certified

diagnostic radiologist and neuroradiologist who is licensed in 29 states. He reads

images for approximately 200 cases daily, has been practicing for 30 years, and has

served as chief of radiology at six hospitals.

{¶45} Dr. Saini explained that, as a radiologist, he interprets images of the

body, including X-rays, CT scans, MRIs, nuclear medicine scans, ultrasound,

fluoroscopy, and pre- and post-surgical imaging. Dr. Saini testified that his

interpretations guide surgeons on whether they performed a procedure correctly,

whether they performed the procedure on the correct body part, or which procedure

should have been done. He further explained the fluoroscopy process and how it helps

to ensure that hardware is correctly placed.

{¶46} In their third assignment of error, Durrani claims that Dr. Saini’s

testimony was improper because his testimony went beyond his expertise. During

trial, Durrani objected to Dr. Saini’s testimony regarding a surgical note and notes

from a physical. Durrani also objected when Dr. Saini began to explain what a

microdiscectomy entailed. Both objections were overruled. We conclude that those

objections were properly overruled because the testimony was within the scope of Dr.

Saini’s expertise. However, as discussed below, as to the portions of Dr. Saini’s

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testimony to which Durrani failed to object, we hold that admission of this testimony

did not constitute plain error.

{¶47} In appeals of civil cases, the plain-error doctrine is not favored; it may

be applied only in the extremely rare case involving exceptional circumstances where

error, to which no objection was made at the trial court, seriously affects the basic

fairness, integrity, or public reputation of the judicial process, thereby challenging the

legitimacy of the underlying judicial process itself. State ex rel. Suburban Driving

School, L.L.C. v. Ohio Bur. of Workers’ Comp., 2026-Ohio-597, ¶ 34. The doctrine

implicates errors that are “obvious and prejudicial although neither objected to nor

affirmatively waived which, if permitted, would have a material adverse [e]ffect on the

character and public confidence in judicial proceedings.” Missionaries of the Sacred

Heart, Inc. v. Ohio Dept. of Youth Servs., 2021-Ohio-1559, ¶ 18, fn. 3.

{¶48} Of the unobjected-to portions of Dr. Saini’s testimony, only Dr. Saini’s

opinion of the placement of an anterior cage during Zurieck’s procedure and that he

would have thought that Dr. Durrani would have first addressed the loosening screws

during Zurieck’s surgery instead of the diseased disc at L1-L2 were questionable. As

Durrani failed to object to these statements, we must determine whether the

admission of those statements constituted plain error. They do not.

{¶49} Even if Dr. Saini’s opinions went beyond his area of expertise, his

testimony regarding Hamilton was echoed by another of plaintiffs’ experts, Dr. Charles

Mehlman, who also opined that Dr. Durrani’s treatment of Hamilton deviated from

the standard of care, and that he directly caused permanent injuries to both patients.

Durrani raises no objection to the admission of Dr. Mehlman’s opinion testimony.

Therefore, even if the trial court erred in permitting Dr. Saini to testify on these issues,

any such error was harmless because there was other testimony on these same issues

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that the jury was able to rely on. Because the admission of Dr. Sani’s testimony was

not prejudicial, Durrani’s third assignment of error is overruled.

E. Set-off

{¶50} In their fourth assignment of error, Durrani argues that they were

entitled to a set-off. Our opinion in Boggs, 2026-Ohio-210, at ¶ 100-101 (1st Dist.),

recognized that this court has held that Durrani is entitled to a set-off based on

plaintiffs’ settlements with other defendants. The same holds true here and the cause

must be remanded to the trial court to determine the set-off amounts to which Durrani

are entitled. The fourth assignment of error is sustained.

F. Prejudgment Interest

{¶51} In their fifth and final assignment of error, Durrani argues the court

erred when it granted plaintiffs prejudgment interest. Durrani’s argument that the

plaintiffs’ $500,000 settlement demands on the date of trial were not made in good

faith has most recently been considered by this court in Boggs. The facts are the same

as in Boggs and other Durrani cases in which we overruled Durrani’s identical

assignment of error. Id. at ¶ 102-112. Our holding in Boggs controls, and therefore,

Durrani’s fifth assignment of error is overruled.

G. Plaintiffs’ Posttrial Motion to Dismiss the Fraud Claim

{¶52} Regarding plaintiffs’ efforts to dismiss their fraud claims, the Ohio

Supreme Court has reconsidered the issue in Clark v. Durrani, 2026-Ohio-846, and

has denied the plaintiffs’ motion. This court follows that holding.

III. Conclusion

{¶53} The judgments of the trial court are affirmed in part and reversed in

part, and the cause is remanded.

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

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CROUSE, P.J., and NESTOR, J., concur.

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