Litigation Byte

Ohio Supreme Court Holds Hearing on Arbitration Not Required if Parties Do Not Request It

June 10, 2025

In a unanimous opinion, the Ohio Supreme Court held that a trial court is not required to first hold an oral hearing on a motion to compel arbitration under Ohio’s Arbitration Act (R.C. 2711 et. seq.) if no party requests a hearing. Ohio courts had been split on whether Ohio’s Arbitration Act required an oral hearing before a court could grant a motion to compel arbitration. But, as the Ohio Supreme Court unanimously found, no such hearing is required if no party requests one under the doctrine of “party presentation.” 

As the Court noted:

“[u]nder the principle of party presentation, ‘we rely on the parties to frame the issues for decision and assign to courts the role of neutral arbiter of matters the parties present.’” In this case, since no party actually requested an oral hearing, the appellate court erred by reversing the trial court’s decision compelling arbitration on the ground that no oral hearing occurred.

Snyder makes clear that if a party desires oral argument on a motion to compel arbitration, it must explicitly request one.