Taylor v. Honda Motorcars, Inc.

135 N.E.3d 1284 (2019)

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Nature of the Case

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Facts

P leased a 2017 Honda Accord from D pursuant to a closed-end vehicle lease agreement. P was the only lessee listed on the lease agreement. P took possession of the vehicle at approximately 7:00 p.m. on October 9. A couple of hours earlier, another Honda Accord had been stolen from D. D contacted the police, reporting that the vehicle had been stolen. Due to an error by D, the vehicle leased by P was assigned the same temporary license plate as the vehicle that had been stolen. Marcia Taylor (P) was driving the vehicle and their minor daughter was a passenger in the vehicle. Police pulled over the vehicle and detained Marcia Taylor (P) and the daughter. The error was discovered and no criminal charges were filed against the Taylors. Shortly thereafter, P returned the leased vehicle to the dealership. D returned the money P had paid under the lease agreement and the parties mutually terminated the agreement. On April 16, 2018, Ps individually and on behalf of their minor daughter, filed a complaint asserting claims of breach of contract, defamation per se/defamation, false arrest/seizure, negligence/negligence per se and punitive damages against D. Ps alleged that D breached the leased agreement when it 'caused the vehicle to be seized by officers as a result of D's negligence. Ps alleged that Marcia Taylor had been 'placed in handcuffs[,] humiliated and embarrassed before the public. Ps claimed that, as a result of D's actions, they had 'suffered economic damages resulting from the loss of use of the automobile,' that 'the lives of * * * Marcia Taylor and her minor daughter were placed at great risk' and that Ps 'suffered severe emotional distress to this day and into the indefinite future.' Ps sought compensatory damages in excess of $25,000, punitive damages, attorney fees, and costs. D filed a motion to dismiss the complaint. The trial court granted D's motion to dismiss on all counts except the claim for breach of contract. On August 9, 2018, D filed a motion for summary judgment on the breach of contract claim. D argued that Ps could not prevail on their breach of contract claim as a matter of law because: (1) they had not suffered any economic damages given that all amounts paid by P pursuant to the lease agreement were returned; (2) a plaintiff cannot recover emotional distress damages on a breach of contract claim under Ohio law and (3) Marcia Taylor and the Taylors' daughter were not parties to the lease agreement and, therefore, lack standing to assert a claim for breach of contract. The trial court granted D's motion for summary judgment. Ps appealed. Ps claim in part that there is a genuine issue of material fact as to whether Marcia Taylor and the Taylors' minor daughter were intended third-party beneficiaries of the agreement.