Background
Jihad Dupuy sued Thanh Nguyen and Amber Nguyen in the Cuyahoga County Court of Common Pleas. After the parties filed cross-motions for summary judgment, the trial court denied Dupuy’s motions and granted summary judgment to the Nguyens on March 19, 2026.
Dupuy appealed. The Eighth District initially struck his appellate brief because it omitted required sections, including assignments of error and separate supporting arguments. Although the court allowed him to submit a corrected brief, his amended filing listed twelve purported assignments of error that identified documents or procedural events rather than alleged erroneous rulings.
The Court’s Holding
The Court of Appeals affirmed. It held that Dupuy’s amended brief failed to comply with Ohio Appellate Rule 16 because it did not separately argue the asserted errors, identify a standard of review, explain how the cited civil rules applied, or show how any claimed procedural issue warranted reversal of the summary-judgment ruling.
Exercising its discretion under Appellate Rule 12(A)(2), the court disregarded and overruled the twelve purported assignments of error rather than dismissing the appeal, as the appellees had requested. Dupuy’s pro se status did not excuse compliance with the appellate briefing rules.
Key Takeaways
- An appellant must identify an actual claimed error and provide a separate, supported argument for each assignment of error.
- Page citations, document references, and general citations to procedural rules do not substitute for legal argument showing prejudicial error.
- Ohio appellate courts need not construct arguments or search the record for a basis to reverse, including for pro se appellants.
Why It Matters
The decision underscores that appellate review depends on properly developed assignments of error tied to the ruling under review. A party who does not explain why a ruling was legally wrong risks having the claimed errors disregarded and the judgment affirmed.