The Ohio Supreme Court reversed the Franklin County Court of Appeals in *Sauter v. Integrity Cycles, L.L.C.*, delivering a 5-2 decision that clarifies timing requirements under Ohio's saving statute and resolves a circuit split on how to calculate the one-year deadline for refiling dismissed claims.
The court held that R.C. 2305.19, Ohio's saving statute, requires plaintiffs to refile dismissed claims within exactly one year of dismissal, rejecting the appeals court's interpretation that would have allowed an additional day beyond the anniversary date. Justice Shanahan authored the majority opinion, joined by Justices Fischer, DeWine, Brunner, and Deters. Chief Justice Kennedy dissented, joined by Justice Hawkins.
The case centers on the interpretation of Ohio Revised Code Section 2305.19, which allows plaintiffs to commence new actions "within one year" after a claim fails otherwise than on the merits. This saving statute serves as a critical safety net for litigants whose cases are dismissed on procedural grounds rather than substantive legal deficiencies.
The Franklin County Court of Appeals had adopted what Justice Shanahan described as the view that "one year" actually means "a calendar year plus a day." Under this interpretation, a claim dismissed on January 5, 2022, could theoretically be refiled as late as January 6, 2023, giving plaintiffs an extra day beyond the strict anniversary date.
The Supreme Court of Ohio rejected this generous interpretation, emphasizing that statutory language should be given its plain meaning. The majority opinion establishes that "one year" means exactly that – 365 days from the date of dismissal, with no additional grace period.
This ruling provides important clarity for Ohio practitioners handling cases where claims have been dismissed on procedural grounds. The saving statute commonly applies in situations involving statute of limitations issues, improper service, jurisdictional defects, or other technical deficiencies that result in dismissal without reaching the merits of the underlying dispute.
The decision resolves what had become a source of confusion in Ohio's intermediate appellate courts. Different districts had adopted varying approaches to calculating the one-year deadline, creating uncertainty for attorneys attempting to advise clients about refiling deadlines.
Under R.C. 2305.19, the saving statute applies when an action "fails otherwise than upon the merits." This language encompasses dismissals for technical reasons that do not address the substantive validity of the plaintiff's claims. The statute serves an important purpose in Ohio's civil justice system by preventing harsh results where litigants lose their right to pursue valid claims due to procedural missteps.
The majority's interpretation aligns with similar statutory construction principles applied in other contexts. Ohio courts generally apply plain meaning rules to statutory interpretation, giving effect to the ordinary understanding of legislative language unless ambiguity requires resort to other interpretive tools.
The dissent, led by Chief Justice Kennedy and joined by Justice Hawkins, apparently disagreed with the majority's strict interpretation, though the full text of their dissenting reasoning was not available in the source materials. Dissenting opinions in saving statute cases often focus on the remedial purpose of such statutes and argue for more generous interpretation to protect litigants' access to courts.
This decision will have practical implications for Ohio civil litigation. Attorneys must now ensure strict compliance with the anniversary date rule when advising clients about refiling options. The ruling eliminates any argument that plaintiffs have until the day after the anniversary to commence new actions.
The case also demonstrates the importance of precise calendar calculations in legal practice. Attorneys handling dismissed cases must carefully track dismissal dates and ensure new actions are filed before the anniversary date expires. Even a one-day delay could now prove fatal to a client's claims.
For Ohio's legal community, the decision provides welcome certainty about saving statute deadlines. The previous circuit split had created practical difficulties for attorneys practicing in multiple districts or handling cases that might be appealed to different courts of appeals.
The Supreme Court's ruling in *Sauter* represents a return to strict statutory interpretation in the saving statute context. While this may seem harsh to some plaintiffs who barely miss the deadline, the majority apparently concluded that clear rules serve the broader interests of predictability and judicial efficiency.
Looking ahead, the decision will likely influence how Ohio attorneys calendar critical deadlines in dismissed cases. Best practices will need to account for the strict anniversary rule, with appropriate buffer time built into filing schedules to avoid last-minute complications.
The case number 2024-0370 was submitted to the Supreme Court on March 12, 2025, and decided on January 15, 2026. The underlying Franklin County Court of Appeals decision was designated 2024-Ohio-309 in case number 23AP-313.