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Setting Aside A Judgment

Ohio Civ.R. 60 — three things, all of them, together

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A judgment already entered can sometimes be set aside, and the route is a motion for relief from judgment. The Supreme Court of Ohio laid out what such a motion has to show in a case from 1976, and courts have been applying the same three part test ever since.

  • A meritorious defence or claim to present if relief is granted.
  • Entitlement to relief under one of the grounds the rule states.
  • A motion made within a reasonable time, and where the ground is one of the first three, not more than one year after the judgment was entered.
All three, together. Two out of three is a denial. The test is conjunctive, which is the single most important thing about it. A person with an unanswerable defence who files two years after the judgment on a ground that carries the one year limit does not get relief, and neither does a person who moves quickly with no defence to offer.
The defence has to be alleged, not proved. The burden on the first element is to allege a meritorious defence, not to prove that the movant will prevail on it. That is a lower bar than people expect, and it is often misread as requiring the whole case to be won inside the motion.

Reasonable time and one year are two separate requirements rather than one. Where the ground carries the one year limit, a motion is still capable of being too late inside the year, because reasonable time applies on its own. The year is a ceiling, not a permission.

The elementWhat satisfies it
A meritorious defenceAlleged, not proved
A ground under the ruleOne of the grounds the rule lists
TimingA reasonable time, and within one year where the ground is one of the first three
Any two of the threeNot enough

The grounds the rule lists, which of them carry the one year limit and which do not, what a court weighs in deciding whether the time was reasonable, and the separate question of a judgment that is void rather than voidable are in the rule and in the cases applying it, and are not reproduced here. Nothing on this page says whether a particular judgment can be set aside. A motion under this rule is a court filing with a form and a standard, and legal aid organisations in Ohio and a licensed Ohio attorney are who prepare one.

Sources for this section (2)
  1. Ohio Civ.R. 60Relief from a judgment or order
  2. GTE Automatic Elec. v. ARC Industries, 47 Ohio St.2d 146 (1976)The three things a motion for relief from judgment has to show

Legal information, not legal advice. Verified as of September 2026. Talk to a licensed Ohio attorney about your situation.

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