Grabowski v. Allstate Ins. Co., 88383 (6-7-2007)

{¶ 27} I concur in the majority opinion but write separately to address the issue of the trial court's improper use of default judgment as a sanction for defendant's failure to appear at a pretrial hearing.

{¶ 28} The trial court erred in granting the default judgment against appellant. This court has made it clear that it is reversible error for a trial court to render default judgment against a defendant once an answer has been filed and the case has been placed at issue. Reese v.Proppe (1981), 3 Ohio App.3d 103. Once a case is at issue, the plaintiff is required to present proof of both…