The Eleventh District Court of Appeals of Ohio has vacated a default judgment against a defendant, Awo D. Addo, ruling that the trial court in Lake County lacked the necessary personal jurisdiction over her. The appellate court found that the evidence presented by Bank of America, N.A. (the bank) was insufficient to establish that Addo had the required “minimum contacts” with Ohio to justify hauling her into an Ohio court.
The decision, issued December 8, 2025, essentially wipes clean a judgment granted in 2020 concerning an unpaid credit account balance of over $11,000.
The Road to Appeal: A Default Judgment and a Late Challenge
The dispute originated from a credit account Addo held with Bank of America. After Addo allegedly failed to make required payments, the bank charged off a balance of $11,431.15. Bank of America filed suit in the Willoughby Municipal Court in December 2019. Because Addo apparently never responded, the court issued a default judgment in March 2020.
Addo waited nearly three and a half years before taking action, filing a motion to vacate the default judgment in October 2023. While the lower court proceedings involved hearings and magistrate decisions, the core issue that reached the appellate court was jurisdiction—specifically, whether the Ohio court had the legal authority to rule against a non-resident defendant in the first place.
The Core Issue: Personal Jurisdiction and “Minimum Contacts”
Addo argued on appeal that the trial court erred because it did not have personal jurisdiction over her, nor was she properly served. The appellate court focused heavily on the first assignment of error: the lack of personal jurisdiction.
For an Ohio court to assert jurisdiction over a non-resident defendant, two hurdles must be cleared: first, the action must fall under Ohio’s “long-arm” statute (R.C. 2307.382); and second, asserting jurisdiction must comply with the Due Process Clause of the Fourteenth Amendment of the U.S. Constitution. This second step requires the defendant to have “purposefully availed” themselves of the privilege of conducting activities within Ohio, creating “minimum contacts” such that forcing them to defend a suit there is fair and reasonable.
The Evidence (or Lack Thereof)
The trial court had justified its jurisdiction based on the fact that Addo had received monthly account statements at her brother’s address in Willoughby, Ohio, between 2015 and 2018.
However, the Eleventh District Court disagreed, emphasizing that jurisdiction cannot rest on minimal or ancillary contacts. The appellate court noted that mere use of interstate mail or telephone service is generally not enough, by itself, to establish the necessary minimum contacts required by due process.
The record showed that Addo did not currently reside in Ohio, and the bank failed to provide any evidence that the contract was formed in Ohio, or that any negotiations or substantive communications took place within the state. Crucially, the record indicated Addo had only visited Ohio once, long before the credit account was established (in 2008).
“As the record is devoid of evidence that Addo had any more contact with the State of Ohio than using interstate mail to receive account statements,” the appellate judges concluded, “the trial court abused its discretion when it adopted the magistrate’s decision, denying Addo’s motion to vacate the default judgment.”
Void Judgment and Moot Issues
The court made it clear: a default judgment rendered by a court without personal jurisdiction is void. Because the first assignment of error regarding jurisdiction was successful, the court ruled that the default judgment against Addo was void and must be vacated.
Since the entire judgment was voided on jurisdictional grounds, Addo’s second assignment of error—concerning whether she was properly served with the complaint—was rendered moot and was not addressed.
The appellate court reversed the decision of the Willoughby Municipal Court and vacated the default judgment, ordering that costs associated with the appeal be taxed against Bank of America.