Rodriguez v. Catholic Charities Corporation, 2025-Ohio-4840
Case Information
Court: Court of Appeals of Ohio, Eighth Appellate District, County of Cuyahoga
Date: 2025-10-23
Citation: 2025-Ohio-4840
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Summary
Summary: This case involves the reversal of a jury verdict in favor of the estate of a deceased child against Catholic Charities Corporation for negligent hiring, supervision, and training of its employee. The appellate court found multiple trial errors, including improper exclusion of expert testimony on causation and failure to properly consider a consent judgment, necessitating a new trial.
Key Holdings
- A trial court must take judicial notice of a consent judgment in the same case if properly requested
- A consent judgment can establish liability even if the party is dismissed from trial
- Expert testimony on causation is admissible if based on probability and relevant specialized knowledge
- A principal may be vicariously liable if the agent’s liability has been judicially established
- Denial of vicarious liability based on Clawson was improper where liability of the agent was not extinguished
More Information
The case arose from the death of a child named Jordan, who was under the care of his mother and her boyfriend. Catholic Charities employee Nancy Caraballo had been assigned to provide parenting services to the family but failed to perform her duties, falsified visit records, and did not report signs of abuse. Caraballo later pled guilty to several criminal charges related to her conduct. Jordan died in 2017 due to severe neglect and abuse.
The estate filed suit alleging wrongful death and other claims. The trial court directed verdicts on certain claims and excluded expert testimony regarding causation, concluding it was speculative. It also excluded a consent judgment (CJE) in which Caraballo admitted liability, despite its relevance.
On appeal, the court found that the trial court erred by excluding the CJE, which had the force of a final judgment and established Caraballo’s liability. The appellate court also held that excluding expert testimony on causation was improper, as the experts provided opinions based on probability and specialized knowledge that were essential to the jury’s understanding.
Additionally, the appellate court found that Catholic Charities could be vicariously liable for Caraballo’s actions because her liability had not been extinguished by settlement. The court distinguished this case from precedent such as Clawson, emphasizing that Caraballo’s liability was judicially established.
Ultimately, the appellate court reversed the trial court’s judgment and remanded the case for a new trial, underscoring the importance of proper evidentiary rulings and jury instructions in complex tort cases involving institutional negligence.