Bank of Am., N.A. v. Addo

Summary

The Eleventh District Court of Appeals of Ohio reversed the Willoughby Municipal Court’s decision adopting a magistrate’s denial of Awo D. Addo’s motion to vacate a default judgment in favor of Bank of America, N.A. The appellate court held that Addo’s contacts with Ohio—primarily directing account statements to be mailed to her brother’s Ohio address—were insufficient to establish personal jurisdiction under Ohio’s long-arm statute and constitutional due process requirements. The default judgment was therefore vacated as void, and the service-of-process assignment of error was rendered moot.

Holdings

1. The trial court lacked personal jurisdiction over Addo because the record showed no Ohio contact beyond use of interstate mail to receive account statements, and that contact was insufficient to constitute purposeful availment or establish the minimum contacts required by Ohio's long-arm statute and due process.
2. The court did not decide whether Addo was properly served because the lack of personal jurisdiction independently required vacatur of the default judgment, rendering the service issue moot.

Questions Presented

1. Whether the trial court had personal jurisdiction over Addo under Ohio's long-arm statute and constitutional minimum-contacts principles.
2. Whether Addo was properly served with the complaint.

Disposition

reversed_and_remanded