Slodov v. Eagle Ridge Subdivision Property Owner’s Assn., Inc.

Summary

The Ohio Eleventh District Court of Appeals affirmed a contempt judgment against Leonard Slodov for failing to provide unfettered access to an homeowners association email account and financial accounting software as required by an agreed judgment entry. The court held that the trial court retained jurisdiction because the agreed entry required both payment and a notice of compliance, and that extending access as a remedial contempt measure was permissible. The court also rejected Slodov’s arguments concerning fiduciary duty and the sufficiency of the contempt proceedings.

Holdings

1. The trial court retained jurisdiction because the agreed judgment entry expressly provided that jurisdiction would continue until payment was received by Eagle Ridge’s counsel and a notice of compliance was filed with the court; no notice of compliance had been filed.
2. The trial court had authority to order access for a longer period than originally contemplated because the additional access was a remedial measure designed to compel compliance with the court’s order and benefit the appellees.
3. The trial court properly found Slodov in civil contempt because clear and convincing evidence established that he failed to provide the unfettered access required by the court’s order.

Questions Presented

1. Whether the trial court retained jurisdiction to enforce the June 17, 2024 agreed judgment entry after Slodov paid the $3,100 sanction.
2. Whether the trial court had authority to order email-account access for a period longer than the period contemplated by the agreed judgment entry as a remedial civil-contempt measure.
3. Whether the trial court properly found Slodov in civil contempt based on clear and convincing evidence that he failed to provide unfettered access to the Eagle Ridge email account.

Disposition

affirmed