Supreme Court Finds Trial Court Should Not Conduct Hearing Neither Party Requested

The Supreme Court of Ohio today vacated an appeals court decision requiring a trial court to hold a hearing that neither party in the case requested.

In a unanimous decision, the Supreme Court reversed the Ninth District Court of Appeals ruling in a home construction contract dispute. The Ninth District found the Medina County Common Pleas Court wrongly decided the case because it did not conduct an oral hearing on the homebuilder’s request to send the matter to arbitration.

Writing for the Court, Justice Daniel R. Hawkins explained the homeowners asked the Ninth District to overrule the Medina County trial court based on the merits of their arguments. The couple did not argue there was a procedural error made when the court did not conduct an in-person hearing. The construction company, Old World Classics, also did not dispute the lack of a hearing.

Justice Hawkins wrote the judicial system “relies on the principle of party presentation, and courts should ordinarily decide cases based on issues raised by the parties.” Instead of sending the case back to the trial court, the Ninth District should consider the couple’s arguments initially presented in their appeal regarding the home construction contract, the Court ruled.

Homeowners Resist Arbitrating Dispute
In 2020, Matthew and Katherine Snyder contracted with Old World Classics to build a home in Medina County. The agreement contained a clause requiring the parties to resolve any dispute through binding arbitration. A dispute arose, and in 2023, the Snyders filed a civil lawsuit against the homebuilder, alleging fraud and breach of contract, among other claims.

Old World asked the common pleas court to stay the case and direct the matter to arbitration, citing the dispute resolution clause in the agreement with the Snyders. The court granted Old World’s request without holding an oral hearing.

The Snyders appealed the decision to the Ninth District. They maintained the trial court should not have sent the case to arbitration and should have ruled the arbitration clause was void. The couple argued they were fraudulently induced into agreeing to the provision.

Based on its own assessment of the case, the Ninth District reversed the trial court’s judgment, finding the court should have conducted an oral hearing. Old World appealed the Ninth District’s decision to the Supreme Court, which agreed to hear the case.

The Ninth District also stated its ruling, which found R.C. 2711.03 requires a trial court to hold an oral hearing on a motion to compel arbitration, conflicts with decisions of two other appellate court decisions. The Supreme Court agreed to consider the conflict among appellate courts.

Supreme Court Examined Appeals Process
Citing the Court’s 2024 Epcon Communities Franchising, LLC v. Wilcox Dev. Group, LLC decision, the opinion stated that the principle of party presentation allows the parties to frame the issues for decision and charges the courts with considering the matters the parties present.

“Here, the record reveals that neither party requested a hearing before the trial court on the motion to stay and compel arbitration and that neither party raised before the Ninth District as an assignment of error on appeal the issue of the trial court’s failure to hold an oral hearing on the motion,” the opinion stated.

The Ninth District violated the party presentation principle when ruling on an issue that neither party raised, the Court concluded. The case was remanded to the Ninth District to consider the homeowners’ claim that the arbitration clause was void and that their case should proceed in trial court rather than go to arbitration.

Because the Ninth District’s decision was vacated, the Court did not address whether R.C. 2711.03 requires a trial court to hold an oral hearing on a motion to compel arbitration.

2023-1616 and 2024-0074. Snyder v. Old World Classics LLC, Slip Opinion No. 2025-Ohio-1875.

View oral argument video of this case.

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