Mid-American Fire & Cas. Co. v. Heasley

In Mid-American Fire & Cas. Co. v. Heasley, 113 Ohio St.3d 133, 2007 Ohio 1248, 863 N.E.2d 142, the Ohio Supreme Court definitively settled whether a de novo review or abuse of discretion standard applies in declaratory judgment actions. After considering the proper standard to apply, the court declined to adopt a de novo review and instead, "reaffirmed that declaratory judgment actions are to be reviewed under an abuse-of-discretion standard." Id. at P14. An abuse of discretion connotes more than a mere error of law or judgment, and instead, requires that the court's attitude was unreasonable, arbitrary or unconscionable. Blakemore v. Blakemore (1983), 5 Ohio St.3d 217, 219, 5 Ohio B. 481, 450 N.E.2d 1140.