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B.G. Staffing, L.L.C. v. LanceSoft Inc.

Citation: 2022 Ohio 2963Docket: C-210511

Court: Ohio Court of Appeals; August 26, 2022; Ohio; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In this case, LanceSoft Inc., operating as Zanett Commercial Solutions, appealed the denial of its motion for relief from a default judgment under Civ.R. 60(B) in favor of B.G. Staffing LLC. The default judgment, awarding B.G. Staffing $145,460, was issued after LanceSoft failed to respond to a service of process. Upon satisfaction of the judgment through garnishment of LanceSoft's customer funds, LanceSoft challenged the judgment, citing lack of personal jurisdiction and excusable neglect. The trial court postponed the Civ.R. 60(B) decision pending an evidentiary hearing, ultimately ruling against LanceSoft, finding the neglect inexcusable. LanceSoft's appeal was dismissed as moot because the judgment had been satisfied, and a stay of execution had not been requested prior to the garnishment, rendering the payment voluntary. The court also rejected LanceSoft’s estoppel argument due to insufficient evidence of misrepresentation by B.G. Staffing. Consequently, the court affirmed the satisfaction of judgment, concluding that no meaningful relief could be granted to LanceSoft.

Legal Issues Addressed

Civ.R. 60(B) Motion for Relief from Judgment

Application: LanceSoft sought to vacate the default judgment under Civ.R. 60(B), but the court found the neglect inexcusable and denied the motion.

Reasoning: The trial court ultimately ruled against LanceSoft’s Civ.R. 60(B) motion, deeming the neglect inexcusable and dismissing the claim of fraud against B.G. Staffing’s counsel.

Estoppel in Mootness Arguments

Application: The court rejected LanceSoft's estoppel argument due to lack of evidence showing misrepresentation by B.G. Staffing.

Reasoning: Since LanceSoft failed to provide evidence of such misrepresentation, its estoppel argument is rejected.

Mootness of Appeal Due to Satisfaction of Judgment

Application: The court determined that an appeal is moot if the judgment has been satisfied, as no effective relief can be granted.

Reasoning: The court agreed and dismissed the appeal as moot, concluding that the satisfaction of the judgment rendered the appeal unnecessary.

Voluntary Payment Doctrine

Application: LanceSoft's failure to request a stay of execution before the judgment was satisfied led the court to classify the payment as voluntary, thus extinguishing its right to appeal.

Reasoning: The court agreed, noting that LanceSoft failed to request a stay of execution before B.G. Staffing satisfied the judgment, which is classified as a voluntary payment, thus extinguishing the right to appeal.