Background
Talisa Williams obtained a vehicle loan and credit-card account from CME Federal Credit Union in October 2020. It was undisputed that she did not make payments required by the agreements. CME sued in Franklin County in May 2025 for breach of contract on both accounts.
Williams did not answer the complaint or dispute the defaults. Instead, she repeatedly sought dismissal or a stay and arbitration, relying on arbitration provisions in a property-insurance agreement and an extended-warranty service agreement connected to the vehicle. The trial court denied those requests on December 10, 2025, and later granted CME summary judgment. Williams appealed on January 21, 2026.
The Court’s Holding
The Tenth District dismissed the appeal as untimely. Although Williams characterized her appeal as challenging the January 9, 2026 summary-judgment entry and merged interlocutory orders, each of her assignments of error challenged the earlier denial of her request to stay the case pending arbitration.
Under R.C. 2711.02(C), an order granting or denying a stay pending arbitration is a final, appealable order. Williams therefore had 30 days from the December 10, 2025 entry—until January 9, 2026—to appeal that ruling. Her January 21 notice of appeal was 12 days late. Her request for reconsideration did not extend the deadline because a motion to reconsider a final judgment in the trial court is a nullity.
Key Takeaways
- An order denying a stay pending arbitration is immediately appealable under R.C. 2711.02(C).
- An appellant must appeal that arbitration-stay ruling within App.R. 4(A)(1)’s 30-day deadline.
- A trial-court motion to reconsider a final judgment does not toll or restart the appellate deadline.
Why It Matters
The decision underscores a procedural trap in Ohio arbitration litigation: a party challenging the denial of an arbitration stay cannot wait for a later merits judgment to appeal the issue. The statutory finality of the stay ruling requires a timely, separate appeal.