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Eagle Loan Co. of Ohio, Inc. v. Bailey

2026-08-31

Summary

Holding. The judgment of the municipal court granting summary judgment was reversed and remanded because the promissory note and payment history submitted in support of the summary judgment motion were not properly authenticated by affidavit as required by civil procedure rules.

Eagle Loan Company sued Bailey in municipal court seeking payment on a promissory note. Eagle Loan filed a motion for summary judgment and attached a promissory note, payment history, and an affidavit from a company official. Bailey challenged the motion, arguing that the documents were not properly authenticated. The municipal court granted summary judgment for Eagle Loan, and Bailey appealed.

The appellate court reversed the judgment, finding that the promissory note and payment history attached to Eagle Loan's motion were not properly authenticated through affidavit as required by civil procedure rules. Although an affidavit from the company official was submitted, it neither referenced nor verified the attached documents. Under Ohio law, documents submitted with a summary judgment motion must be authenticated by an averment in an affidavit stating they are true copies, or else they cannot be considered as evidence. The court rejected Eagle Loan's argument that Bailey's general denial in her answer constituted an admission of authenticity.

The court also addressed Bailey's other arguments on appeal. Bailey argued that discovery was still ongoing, but she had not invoked the proper rule to request a continuance for additional discovery. The court found no statute of limitations problem, as the suit was filed in time under Ohio's applicable deadline. The case was remanded to the municipal court for further proceedings, allowing Eagle Loan to file a new summary judgment motion with properly authenticated evidence if it chose to do so.

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

Key issues

  • Authentication requirements for documents submitted with a summary judgment motion
  • Whether an unverified promissory note and payment history can support summary judgment
  • Effect of a general denial in an answer on document authenticity
  • Statute of limitations for written contracts under Ohio law

Procedural posture

This is an appeal from a municipal court's grant of summary judgment in a debt collection action.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

[Cite as Eagle Loan Co. of Ohio, Inc. v. Bailey, 2026-Ohio-3396.]

IN THE COURT OF APPEALS OF OHIO

ELEVENTH APPELLATE DISTRICT

LAKE COUNTY

EAGLE LOAN COMPANY CASE NO. 2026-L-0032 OF OHIO, INC.,

Plaintiff-Appellee, Civil Appeal from the

Mentor Municipal Court

- vs -MARIAH M. BAILEY, Trial Court No. 2025 CVF 00952

Defendant-Appellant.

OPINION AND JUDGMENT ENTRY

Decided: August 31, 2026

Judgment: Reversed and remanded

Thomas M. Glennon, Glennon Law Firm, L.L.C., 1060 Nimitzview Drive, Suite 100, P.O. Box 30465, Cincinnati, OH 45230 (For Plaintiff-Appellee).

Mariah M. Bailey, pro se, 668 Monticello Place Lane, Cleveland, OH 44143 (DefendantAppellant).

SCOTT LYNCH, J.

{¶1} Defendant-appellant, Mariah M. Bailey, appeals the grant of summary

judgment in favor of plaintiff-appellee, Eagle Loan Company of Ohio, Inc., in the Mentor

Municipal Court. Eagle Loan supported its Motion for Summary Judgment with a copy of

a promissory note and payment history. However, these documents were not properly

authenticated by affidavit and Bailey duly challenged the lack of proper authentication.

Accordingly, we reverse the judgment of the court below.

Substantive and Procedural History

{¶2} On July 25, 2025, Eagle Loan filed a Complaint against Bailey in the Mentor Municipal Court seeking judgment on a promissory note in the amount of $1,912.76 plus

interest.

{¶3} On January 5, 2026, Eagle Loan served Bailey with a Motion for Summary

Judgment.1 Attached to the Motion were a Note executed by Bailey as borrower and

Eagle Loan as payee on April 30, 2019, with a principal amount of $2,070.55, and the

payment history. Also attached was the Affidavit of Eric Johansen, “an Official

Representative and/or Manager for Plaintiff … duly authorized to execute this Affidavit on

behalf of the Plaintiff.” Johansen averred in relevant part:

(2) Affiant is personally familiar with the delinquent account of

MARIAH M BAILEY[.]

(3) The Defendant(s) defaulted upon the repayment provisions of the

contract as executed by the Defendant(s).

(4) The total sum due and owing on said account, including accrued

interest and proper credit for all payments and offsets, is $1912.76

as of 11/20/2019 with interest accruing thereafter at the Contract rate

of 25.0000% per annum.

{¶4} On January 14, 2026, Bailey filed a Motion to Strike Plaintiff’s Affidavit and

an Opposition to Plaintiff’s Motion for Summary Judgment.

{¶5} On March 24, 2026, the municipal court granted Eagle Loan’s Motion for

Summary Judgment and entered judgment accordingly.

Assignments of Error

{¶6} On April 1, 2026, Bailey filed a Notice of Appeal. On appeal, she raises the

following assignments of error:

[1.] Summary judgment was improper.

[2.] Summary judgment was premature.

1. For reasons not apparent from the face of the record, the Motion was not filed and/or docketed until January 20, 2026.

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[3.] Legal issues were improperly resolved.

Standard of Review

{¶7} “Summary judgment shall be rendered forthwith if the pleadings,

depositions, answers to interrogatories, written admissions, affidavits, transcripts of

evidence, and written stipulations of fact, if any, timely filed in the action, show that there

is no genuine issue as to any material fact and … the moving party is entitled to judgment

as a matter of law,” i.e., when “reasonable minds can come to but one conclusion and

that conclusion is adverse to the party against whom the motion for summary judgment

is made, that party being entitled to have the evidence or stipulation construed most

strongly in the party’s favor.” Civ.R. 56(C).

{¶8} “When reviewing the decision of a trial court granting or denying a party’s

motion for summary judgment, an appellate court applies a de novo standard of review.”

Smathers v. Glass, 2022-Ohio-4595, ¶ 30. “The appellate court conducts an independent

review of the evidence without deference to the trial court’s findings.” Id. “It examines

the evidence available in the record, including deposition or hearing transcripts, affidavits,

stipulated exhibits, and the pleadings, see Civ.R. 56(C), and determines, as if it were the

trial court, whether summary judgment is appropriate.” Id. When a party seeks to resolve

a case on summary judgment, the evidence cannot be weighed, only reviewed de novo.

Id. at ¶ 32. “When factual ambiguities exist,” and even when they do not, “inferences

must still be resolved in favor of the nonmoving party.” Id.

Compliance with Appellate Rule 16

{¶9} “The appellant shall include in its brief … [a]n argument containing the

contentions of the appellant with respect to each assignment of error presented for review

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and the reasons in support of the contentions, with citations to the authorities, statutes,

and parts of the record on which appellant relies.” App.R. 16(A)(7); compare Loc.App.R.

16(B)(4) (“[t]he Assignments of Error shall assert precisely the manner in which the trial

court is alleged to have erred”) and (B)(4)(a) (“[t]he statement of the Assignments of Error

is not complete without citation to that portion of the record before the court on appeal

wherein the lower court committed the error complained of”).

{¶10} Bailey’s brief fails to contain any citations to the record or legal authority.

Pursuant to this Court’s Local Rules, Bailey’s failure “may result in the brief being stricken

… and/or in the dismissal of the appeal.” Loc.App.R. 16(D).

{¶11} Despite the lack of compliance, this Court has reviewed arguments on

appeal in the interest of justice when the substance of the arguments may be reasonably

discerned. See, e.g., Estate of Andolsek, 2025-Ohio-5286, ¶ 16 (11th Dist.); Briggs v.

Link, 2022-Ohio-4249, ¶ 9 (11th Dist.). Such review is merited in the present case

inasmuch as Bailey’s arguments were duly raised in the municipal court and given the

nature of our review of summary judgment proceedings, i.e., a de novo or independent

review.

First Assignment: Challenged Evidence

{¶12} In the first assignment of error, Bailey’s argument consists of the following

statement: “Defendant raised valid defenses and challenged evidence.” In the court

below, Bailey argued that the business records submitted by Eagle Loan were not

“properly authenticated.”

{¶13} Regarding the evidence that may be used to support a motion for summary

judgment, the Supreme Court of Ohio has stated:

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Because granting summary judgment under Civ.R. 56(C) terminates

litigation without a trial on the merits, “[t]he requirements of the rule

must be strictly enforced.” Murphy v. Reynoldsburg, 65 Ohio St.3d

356, 360, 604 N.E.2d 138 (1992). Civ.R. 56(C) sets forth the types

of evidence that may be considered in granting a motion for summary

judgment—namely, “pleadings, depositions, answers to

interrogatories, written admissions, affidavits, transcripts of

evidence, and written stipulations of fact.” When deciding a

summary-judgment motion, it is generally error for a court to rely on

other types of evidence that has not been authenticated by way of

an attached affidavit. State ex rel. Boggs v. Springfield Local School

Dist. Bd. of Edn., 72 Ohio St.3d 94, 97, 647 N.E.2d 788 (1995);

Rogoff v. King, 91 Ohio App.3d 438, 446, 632 N.E.2d 977 (8th

Dist.1993) (“The proper procedure for the introduction of evidentiary

matter not specifically authorized by Civ.R. 56(C) is to incorporate

the material by reference into a properly framed affidavit”).

State ex rel. Parker v. Russo, 2019-Ohio-4420, ¶ 10; State ex rel. Ames v. Portage Cty.

Solid Waste Mgt. Dist. Bd. of Commrs., 2024-Ohio-894, ¶ 11-13 (11th Dist.).

“[D]ocuments attached to an affidavit submitted in support or opposition to summary

judgment generally may be authenticated by an averment in the affidavit that the copies

are ‘true copies and reproductions.’” PNC Bank, Natl. Assn. v. Graham, 2022-Ohio-888,

¶ 15 (11th Dist.), quoting State ex rel. Corrigan v. Seminatore, 66 Ohio St.2d 459, 467

(1981).

{¶14} In the present case, neither the Note nor the payment history were properly

authenticated (or even referenced) by Johansen’s Affidavit. Accordingly, they could not

be considered in rendering summary judgment. Capital One Bank (USA), N.A. v. Tenney,

2011-Ohio-4305, ¶ 27 (11th Dist.) (“[i]t is well-settled that a trial court commits prejudicial

error in considering unverified documents in conjunction with a motion for summary

judgment if the authenticity of the documents is disputed”); U.S. Bank, N.A. v. Richards,

2010-Ohio-3981, ¶ 17 (9th Dist.) (“the copy of the promissory note attached to U.S. Bank’s

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renewed motion for summary judgment was not incorporated into an affidavit, and thus it

was not appropriately considered as evidence under Civ.R. 56”).

{¶15} Without the existence and terms of the loan evidenced by the Note,

Johansen’s Affidavit is insufficient to establish Eagle Loan’s entitlement to judgment as a

matter of law. The Affidavit attests none of the terms of the agreement upon which Bailey

is claimed to have defaulted. Compare Bank of Am. v. Smith, 2014-Ohio-2845, ¶ 11 (1st

Dist.) (“[w]here … a party seeks to enforce its rights under the terms of a written

agreement, the party must produce the writing itself–or some acceptable explanation as

to why that document cannot be produced”).

{¶16} In BAC Home Loans Servicing, L.P. v. Vanjo, 2015-Ohio-4317 (11th Dist.),

this Court affirmed a grant of summary judgment despite the failure to authenticate the

loan documents by affidavit where the documents were attached to the complaint and the

defendants, in their answer, admitted to their authenticity. In the present case, Eagle

Loan likewise attached the Note to its Complaint and argued that, “[i]n her answer,

Defendant admits to entering into the loan contract.” Brief of Plaintiff-Appellee at 5.

Bailey, however, did not admit to its authenticity but, rather, “denie[d] the allegations in

Plaintiff’s Complaint and demand[ed] strict proof thereof.”

{¶17} Finally, we acknowledge that, while the Rules of Evidence do not apply in

small claims proceedings, see Evid.R. 101(D)(8), summary judgment has its own

standards appropriate for the termination of litigation without trial. It has been observed:

[T]he requirement for authentication of materials submitted on a

Civ.R. 56 motion is encompassed in that civil rule and not the rules

of evidence. This presents a peculiar anomaly. The unauthenticated

Warren County complaint and letters of the plaintiff could be

considered at trial because the rules of evidence don’t apply, but they

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can’t be considered on summary judgment because they don’t

comply with Civ. R.56.

Folck v. Khanzada, 2012-Ohio-4971, ¶ 8, fn. 1 (2d Dist.).

{¶18} Accordingly, this matter is remanded for further proceedings. As to the

nature of these proceedings, this Court has held as follows: “The doctrine of the law of

the case does not foreclose a party from filing, nor the court from considering, a new

motion for summary judgment, notwithstanding that the trial court, in the same case, had

previously granted summary judgment, which judgment was subsequently reversed on

appeal, where such new motion is based upon an expanded record.” (Citation omitted.)

Ohio Receivables, L.L.C. v. Purola, 2013-Ohio-5806, ¶ 11 (11th Dist.).

{¶19} The first assignment of error is with merit.

Second Assignment: Outstanding Discovery

{¶20} Bailey’s second argument for reversal is that “[d]iscovery was ongoing and

not fully resolved when judgment was granted.”.

{¶21} Eagle Loan correctly notes that no discovery was actually pending at the

time summary judgment was granted.

{¶22} Moreover, Bailey did not avail herself of Civil Rule 56(F): “Should it appear

from the affidavits of a party opposing the motion for summary judgment that the party

cannot for sufficient reasons stated present by affidavit facts essential to justify the party’s

opposition, the court may refuse the application for judgment or may order a continuance

to permit affidavits to be obtained or discovery to be had or may make such other order

as is just.”

{¶23} Bailey did not motion the municipal court for a continuance or submit an

affidavit providing sufficient reasons why she could not present facts essential to oppose

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summary judgment. Where a party fails to do so, the court may grant summary judgment

even if requests for discovery were pending. In re Estate of Beatley v. Fisher, 2024-Ohio5109, ¶ 42 (10th Dist.); Mitchell Family Trust Fund v. Cole, 2026-Ohio-744, ¶ 16 (8th Dist.)

(“[t]o properly invoke Civ.R. 56(F), a party is required to file a motion for a continuance

and an affidavit pursuant to the subsection explaining its need for additional discovery to

obtain facts necessary to oppose the opposing party’s summary judgment motion”).

{¶24} The second assignment of error is without merit.

Third Assignment: Statute of Limitations

{¶25} In her third assignment of error, Bailey argues that the “[s]tatute of

limitations was disputed and required further analysis before resolution.” Bailey raised

this issue in her Answer and Opposition to Summary Judgment.

{¶26} The current version of R.C. 2305.06, effective June 16, 2021, provides that

“an action upon a specialty or an agreement, contract, or promise in writing shall be

brought within six years after the cause of action accrued.” Prior to June 16, 2021, the

statute of limitations was eight years. Section 4 of S.B. 13, amending R.C. 2305.06 in

2021, provides: “For causes of action that are governed by section 2305.06 of the Revised

Code and that accrued prior to the effective date of this act, the period of limitations shall

be six years from the effective date of this act or the expiration of the period of limitations

in effect prior to the effective date of this act, whichever occurs first.”

{¶27} Six years from the effective date of S.B. 13 is 2027 while eight years from

the date of accrual (inasmuch as Bailey’s alleged breach occurred sometime in 2019)

would be 2026. The present cause of action was filed in 2025. There is no issue with

the statute of limitations.

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{¶28} The third assignment of error is without merit.

{¶29} For the foregoing reasons, the judgment of the Mentor Municipal Court is

reversed and this case is remanded for further proceedings consistent with this Opinion.

Costs to be taxed against the appellee.

MATT LYNCH, P.J.,

EUGENE A. LUCCI, J.,

concur.

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JUDGMENT ENTRY

For the reasons stated in the Opinion of this court, the first assignment of error is

with merit and the second and third assignments are without merit. The order of this court

is that the judgment of the Mentor Municipal Court is reversed and remanded.

Costs to be taxed against appellee.

JUDGE SCOTT LYNCH

PRESIDING JUDGE MATT LYNCH,

concurs

JUDGE EUGENE A. LUCCI,

concurs

THIS DOCUMENT CONSTITUTES A FINAL JUDGMENT ENTRY

A certified copy of this opinion and judgment entry shall constitute the mandate

pursuant to Rule 27 of the Ohio Rules of Appellate Procedure.

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