City of Richmond Heights v. Robert L. Turner, et al.

Summary

The Eighth District Court of Appeals affirmed a Lyndhurst Municipal Court judgment awarding the City of Richmond Heights $2,284.75 in unpaid municipal income taxes, plus interest and costs, against Robert L. Turner and LaTanya Turner jointly and severally. The court overruled Turner’s assignments of error because he failed to provide a transcript or other record materials necessary to evaluate his claims. The court also noted that Turner could not represent the codefendant, LaTanya Turner, in the appeal.

Holdings

1. When portions of the transcript necessary to resolve assigned errors are omitted from the record, the reviewing court must presume the validity and regularity of the lower court's proceedings and affirm.
2. A pro se litigant is held to the same procedural standards as a represented litigant and is not excused from the duty to file the portions of the record necessary for appellate review.

Questions Presented

1. Whether the appellate court could review Turner's challenges to the City's authority, standing, jurisdiction, alleged contract requirements, and asserted bankruptcy protections when Turner failed to file a transcript or an authorized alternative record.
2. Whether the municipal court judgment should be affirmed in the absence of a record demonstrating error.

Disposition

affirmed