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How Do Courts Determine If a Fiduciary Duty Was Breached in Ohio?

How Do Courts Determine If a Fiduciary Duty Was Breached in Ohio?

October 4, 2024 

In Ohio, fiduciary duty is taken very seriously in legal contexts involving business relationships, estate management, and trustee responsibilities. When someone accepts a fiduciary role, they are legally obligated to act in the best interest of the party they serve. But what happens when a fiduciary is accused of breaching that duty? Determining whether a breach occurred requires the courts to evaluate several factors to ensure that the fiduciary’s actions (or inactions) are thoroughly examined.

What Is Considered a Fiduciary Duty in Ohio?

Before understanding how courts determine if a breach occurred, it’s essential to define what constitutes a fiduciary duty in Ohio. A fiduciary duty exists when a party, known as the fiduciary, is required to act in the best interest of another party, known as the principal. Common fiduciary relationships include business partners, corporate officers, trustees, and legal guardians. Under Ohio law, a fiduciary must adhere to the duties of loyalty, care, good faith, and full disclosure. This means that they must prioritize the interests of the principal over their own, act with diligence and competence, and avoid conflicts of interest.

For example, a trustee managing an estate in Columbus must ensure that they are making decisions that benefit the beneficiaries, not themselves. Similarly, a business partner in Cleveland must be transparent in their financial dealings and avoid taking actions that would harm the business or the other partner’s interests. If a fiduciary fails to meet these obligations, the principal can take legal action for a breach of fiduciary duty.

What Are the Elements of a Breach of Fiduciary Duty Claim in Ohio?

To successfully prove a breach of fiduciary duty in an Ohio court, the plaintiff must establish three key elements:

  1. Existence of a Fiduciary Relationship: The first step is to prove that a fiduciary relationship existed between the parties. This means showing that the defendant had a legal or ethical obligation to act in the plaintiff’s best interest. The relationship must involve a high level of trust and reliance, such as the one between a trustee and a beneficiary or a corporate director and a shareholder.
  2. Breach of Fiduciary Duty: Next, the plaintiff must demonstrate that the fiduciary failed to uphold their duty. This could involve actions such as misusing funds, failing to disclose important information, making decisions that benefit themselves over the principal, or engaging in self-dealing. The plaintiff must show that the fiduciary did not act in good faith or with the required level of care and loyalty.
  3. Damages Resulting from the Breach: Finally, the plaintiff must prove that the breach caused them harm. This harm can be financial, such as lost assets or profits, or non-financial, such as damage to a business’s reputation. The plaintiff must draw a direct link between the fiduciary’s breach and the resulting damages to have a successful claim.

Each of these elements must be proven with clear and convincing evidence. Failing to establish even one of these components can result in the dismissal of the breach claim.

How Do Ohio Courts Assess a Breach of Fiduciary Duty?

When determining whether a fiduciary duty was breached, Ohio courts analyze the actions of the fiduciary in light of the duties they were supposed to uphold. The courts typically ask the following questions:

  • Did the fiduciary act in the best interest of the principal, or did they prioritize their own interests?
  • Were there any conflicts of interest that the fiduciary failed to disclose?
  • Did the fiduciary provide full and accurate information to the principal, or did they withhold critical details?
  • Did the fiduciary exercise the appropriate level of care and diligence expected in their role?

The answers to these questions help the court determine whether the fiduciary acted in good faith or if their actions constituted a breach. In business contexts, for instance, the court may evaluate whether a corporate officer misused company funds or made decisions that unfairly favored certain shareholders. In estate cases, the court may review whether a trustee managed the assets responsibly or engaged in activities that diminished the estate’s value.

The standard of proof in Ohio breach of fiduciary duty cases is “preponderance of the evidence,” meaning that it is more likely than not that the breach occurred. However, in some cases—particularly those involving claims of fraud—the standard may be higher, requiring clear and convincing evidence. This distinction is important because it influences the strength of the evidence needed to succeed in a claim.

Defenses Against a Breach of Fiduciary Duty Claim

Fiduciaries facing allegations of a breach have several defenses they can use, depending on the circumstances of the case. Common defenses include:

  • Consent: If the principal consented to the fiduciary’s actions, even if those actions would normally constitute a breach, the fiduciary can argue that there was no violation of duty.
  • Good Faith: A fiduciary can claim that they acted in good faith and believed their decisions were in the principal’s best interest. This defense is often used when the fiduciary’s actions are being questioned due to poor outcomes rather than intentional misconduct.
  • Statute of Limitations: In Ohio, the statute of limitations for breach of fiduciary duty claims is generally four years. If the claim is filed after this period, the fiduciary can argue that the lawsuit should be dismissed.
  • Business Judgment Rule: In business cases, fiduciaries can invoke the business judgment rule, which protects corporate directors and officers who make decisions in good faith and with reasonable care, even if those decisions result in losses.

Understanding these defenses is critical for both fiduciaries and those considering filing a breach of duty claim. If you’re uncertain about whether a fiduciary’s actions constitute a breach, speaking with an experienced attorney is essential to evaluate the strength of your case.

What Are the Potential Consequences of a Breach of Fiduciary Duty in Ohio?

The consequences for breaching a fiduciary duty in Ohio can be severe, depending on the nature of the breach and the resulting damages. Fiduciaries found in breach may face the following penalties:

  • Financial Damages: The court may order the fiduciary to pay compensatory damages to the plaintiff to cover any financial losses incurred due to the breach. In cases of willful misconduct, punitive damages may also be awarded.
  • Forfeiture of Fees: If the fiduciary was compensated for their role (such as a trustee or corporate officer), they may be required to forfeit their fees or salary as a penalty.
  • Removal from Position: A fiduciary who breaches their duty can be removed from their position. For example, a trustee can be replaced, or a corporate officer can be terminated.
  • Legal Costs: In some cases, the fiduciary may be required to pay the plaintiff’s legal fees if the breach was particularly egregious.

If you are involved in a fiduciary dispute, understanding your rights and options is crucial. Ohio courts take breaches of fiduciary duty very seriously, and the outcomes of these cases can have long-term consequences for both parties.

Contact Daniel McGowan for Help with Breach of Fiduciary Duty Cases

At the Law Offices of Daniel McGowan, we have extensive experience handling breach of fiduciary duty cases in Ohio. Whether you’re a beneficiary dealing with a problematic trustee or a business partner facing allegations of misconduct, we can help. Contact us today to discuss your situation and learn more about how we can protect your interests. With our guidance, you can ensure that your rights are upheld, and the fiduciary is held accountable for their actions.

A recent study published in the Journal of Elder Abuse & Neglect- Developing an Undue Influence Screening Tool for Adult Protective Services, ultimately resulted in a comprehensive practical evaluation guide for estate planning attorneys and elder abuse investigators and concerned family members. In this screening tool and its instructions are definitions of undue influence and the list of "signposts" and "red flags" recognized by Judges and Juries in Courts across the country when faced with probate cases involving claims of undue influence.

For an excellent presentation of useful tools for stopping financial exploitation of the elderly, Dr. Bonnie Levin, Ph.D, University of Miami The Exploitable Brain: Clues to Prevent Exploitation of the Elderly.

Law Offices of Daniel McGowan, LLC is a full-service law practice, with extensive experience in the areas of litigation and trial practice, elder law, and probate law and trust law. The information on this website, however, is not, nor is it intended to be, legal advice. Each legal situation is unique and you should consult with a reputable attorney regarding your specific circumstances.
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