Embassy Healthcare v. Cora S. Bell, Case No. 2017-1031
Twelfth District Court of Appeals (Warren County)

ISSUES:
- Does R.C. 2117.06(C), which involves a creditor's claims against a deceased person's estate, mandate that a claim based on R.C. 3103.03, which describes certain requirements a spouse has to supply "necessaries" to the other spouse, must first be made to the decedent's estate?
- If a creditor doesn't timely file a claim against a decedent's estate, is it impossible to prove that the decedent is unable to pay the claim and, as a result, a claim against the spouse under R.C. 3103.03 is barred?

BACKGROUND:
Cora Bell's husband moved into Carlisle Manor Health Care, a skilled nursing care facility in Warren County, in January 2014, and he died on May 22, 2014. In November 2014, Embassy Healthcare, which operates Carlisle, sent a letter to Bell about payment of her husband's outstanding bill of $1,678.