A recent decision from the Ohio Sixth District Court of Appeals has confirmed that a borrower must repay a disputed student loan debt after courts found sufficient evidence supporting the lender’s claim. The appellate ruling affirms an earlier summary judgment granted to U.S. Asset Management, Inc., which sought to collect on a promissory note originally issued for educational expenses.
According to court documents, U.S. Asset Management, Inc. filed its complaint in Wood County Court of Common Pleas on December 4, 2024, naming Jared Howansky as defendant. The company alleged that Howansky executed a promissory note for funds disbursed by Sallie Mae and that U.S. Asset Management later purchased this note from Sallie Mae in 2020. The complaint included documentation such as an electronically signed copy of the promissory note, the bill of sale transferring ownership of the debt, and correspondence notifying Howansky of the change in creditor.
U.S. Asset Management claimed that at the time of purchase, the outstanding balance was $9,146.91 with accrued interest totaling $6,171.06 and costs amounting to $33.66. The lender asserted it was entitled to enforce payment as assignee of the note.
Howansky responded to these allegations pro se on March 14, 2025, denying knowledge or responsibility for the debt and challenging whether his signature established any valid or enforceable obligation. He further argued that no adequate documentation or complete payment history had been provided to establish default or prove that any claim was within the applicable statute of limitations.
On March 31, 2025, Howansky moved for summary judgment himself, contending that insufficient evidence existed regarding payment activity within any statutory period and raising concerns about documentation completeness. In response, U.S. Asset Management submitted additional records including account statements and a notice of submission filed April 1, 2025. The company argued Utah law governed the contract and that its six-year statute of limitations applied; since their claim was filed less than six years after Howansky’s last payment in January 2019, they maintained it was timely.
The record shows Howansky continued to file various motions—including attempts to dismiss based on procedural grounds such as service issues—and reserved rights to assert claims under federal statutes like Fair Debt Collection Practices Act and Ohio Consumer Sales Protection Act; however, he did not formally amend his pleadings to include these counterclaims.
On April 24, 2025, U.S. Asset Management moved for summary judgment with an affidavit verifying account details and supporting documents including the original promissory note dated May 28, 2015 (with funds disbursed July 30), billing statements showing balances due as late as June 19, 2019 ($9,742.63), and confirmation that no payments were made after January 11, 2019.
In opposition filings described by the court as limited in substance—primarily reiterating jurisdictional objections—Howansky did not address or rebut evidence regarding liability or amounts owed.
The trial court denied Howansky’s motion for summary judgment on June 16, 2025 while granting summary judgment for U.S. Asset Management. It found USAM had properly authenticated business records supporting its claim: “USAM provided evidence to support its claim to collect the debt owed and that Howansky did not dispute the facts.” The trial court also determined USAM’s complaint was timely under Utah law’s six-year limitation period and rejected procedural challenges related to service because they were not raised as affirmative defenses.
Howansky appealed this decision arguing two main errors: first—that incompetent evidence had been relied upon contrary to rules governing admissibility under Civil Rule 56(E); second—that the burden of proof had been improperly shifted onto him before USAM met its own evidentiary burden.
The appellate panel reviewed these arguments together but ultimately affirmed the lower court’s decision after finding USAM had met all requirements under Ohio law for summary judgment motions: “Considering the record…USAM supported its motion for summary judgment with authenticated business records.” The panel noted Howansky failed to object specifically or present contrary evidence regarding key facts: “Lacking any challenge…the trial court was free to consider the evidence.” Thus they concluded there was no genuine issue remaining for trial.
As a result of this ruling—which includes orders for repayment totaling $9,146.91 plus accrued interest ($6,171.06), post-judgment interest at eight percent per annum from date of judgment onward, and costs—Howansky is responsible for all amounts specified in favor of U.S. Asset Management.
Attorneys listed in connection with this case are Jared Howansky representing himself (appellant) and Matthew L. Schrader representing U.S. Asset Management (appellee). Judges Christine E. Mayle, Gene A. Zmuda (authoring judge), and Charles E. Sulek concurred in affirming case number WD-25-043.
Source: 2026Ohio1170_US_Asset_Management_Inc_v_Howansky_Opinion_Ohio_Court_of_Appeals.pdf
