As an associate attorney in the firm’s Casualty Department, Adam concentrates his practice on general liability litigation and also includes automobile liability, trucking & transportation, construction injury, rideshare liability and product liability. He defends corporations, organizations, and their employees in contract and tort matters, including workplace and construction accidents, motor vehicle claims, and wrongful death actions.
Adam earned his J.D., magna cum laude, from Cleveland State University College of Law, where he served as Executive Editor of the Cleveland State Law Review and participated in the Entrepreneurial Law Organization and the Entertainment and Sports Law Association. He also gained probate experience through an internship at a boutique firm, drafting wills, trusts, and memoranda on a range of estate-related issues.
Before law school, Adam completed his Bachelor of Arts in political science, with a minor in philosophy, at The Ohio State University. During his undergraduate years, he contributed to the Do Good Be Great Organization, helping raise funds for cancer research.
Adam first joined Marshall Dennehey in February 2024 as a law clerk in the Cleveland office, later advancing into the firm’s summer law clerk program before transitioning to his current associate role. In addition to his professional work, Adam is actively involved in community service across Ohio, volunteering with the Center of Hope Food Pantry, Eastwoods Elementary School as a classroom assistant, and the Akron-Canton Regional Foodbank.
Thought Leadership
Case Law Alerts
Barking Up the Wrong Tree? How the Supreme Court of Ohio Shortened the Leash on Landlord Liability for Statutory Dog-Bite Claims
July 20, 2026
In a recent 5-2 decision, the Supreme Court of Ohio addressed whether the owner of a manufactured-home community that permits leashed dogs in common areas is a “harborer” of a dog under R.C. 955.28(B), Ohio’s dog-bite statute, which imposes strict liability on the “owner, keeper, or harborer of a dog” for injuries it causes, subject to limited exceptions. The case arose after a child was bitten in the face by a tenant’s dog while playing on a playground within the defendant’s community. The plaintiff alleged that the community owner was a “harborer” of the dog that bit him and, therefore, strictly liable for his injuries. Although the Second District Court of Appeals agreed, the Supreme Court of Ohio accepted the case to determine the meaning of “harborer” under the statute. Applying its plain and ordinary meaning, the Court held that to “harbor” a dog means to shelter, protect, or exercise control over it. While Ohio’s courts of appeals have long described a harborer as someone who has possession and control of the premises where the dog lives and silently acquiesces to its presence, the Court clarified that mere acquiescence is not enough; to harbor a dog requires one to actively shelter, protect, or exercise control over it. Because Sun did not shelter, protect, or exercise control over the tenant’s dog, the Court concluded it was not a harborer of it. This decision significantly changes how statutory dog-bite claims against landlords and other property owners will be analyzed. Specifically, rather than focusing on who controls the premises where the dog is kept, courts must now focus on who controls the dog itself. As a result, it will be considerably more difficult to classify landlords as harborers under R.C. 955.28(B). Importantly, the decision does not eliminate a property owner’s liability for common-law negligence claims. Property owners may still face liability if, for example, they knew of a dog’s repeated aggressive behavior or ignored lease violations. The decision narrows only one avenue of recovery. Landlords should still enforce their pet policies, document complaints, and respond to reports of dangerous animals. Nonetheless, for landlords and their insurers, this opinion provides a meaningful new defense against statutory dog-bite claims. Ownership or maintenance of common areas, standing alone, no longer automatically exposes a property owner to strict liability for injuries caused by a tenant’s dog. Plaintiffs will need stronger evidence that the defendant actively sheltered, protected, or exercised control over the dog that caused the injury.
Case Law Alerts
Linking Riders, Not Liability: Limits on Duty for Rideshare Platforms
April 1, 2026
In Cooper, the Second District Court of Appeals addressed whether a transportation network company (TNC) owes a duty of care to a driver harmed while using its platform. The plaintiff argued that a TNC owes a duty to its drivers based on its control over the rideshare platform, its safety policies, and its role in matching drivers with riders. The court, however, analyzed duty through traditional Ohio negligence principles governing entities that engage independent contractors, emphasizing that a hiring entity is generally not liable for injuries arising from the contractor’s work absent specific exceptions. Central to the court’s reasoning was the “active participation” doctrine, which limits when a company who hires an independent contractor assumes a duty of care. Under Ohio law, active participation requires more than general oversight, arising only when the hiring entity directs the injury-causing activity, gives or denies permission for the critical act, or retains control over a key variable in the work. Applying this framework, the court rejected the argument that Lyft’s operation of its platform—such as allowing users to create accounts or assigning ride requests—constituted active participation. The court also clarified that a TNC’s general safety measures, policies, and monitoring capabilities do not, standing alone, create a duty. Consistent with longstanding precedent, retaining authority to enforce safety standards or coordinate activity does not rise to active participation. The decision is particularly relevant because it suggests that platform-based controls—such as algorithmic dispatch, account verification, or general safety rules—are analogous to supervisory functions traditionally insufficient to impose a duty on a company hiring independent contractors. Thus, even where a TNC has superior knowledge or implements safety-related systems, those features must be tied directly to the injury-producing act to establish duty. Finally, Cooper reinforces the importance of the independent-contractor relationship in limiting negligence liability for TNCs. By treating drivers as independent contractors, it restricts when a hiring entity owes a duty for injuries arising from the contractor’s work. The ruling signals that, absent evidence of control over the specific conduct causing harm, courts are unlikely to expand duty based solely on a TNC’s platform design or contractual safety commitments. For negligence claims against TNCs, generally, Cooper underscores that liability will turn not on the existence of platform-level control in the abstract, but on whether the company meaningfully controlled—or actively participated in—the precise risk that resulted in the plaintiff’s injury.
