Baber v. Mikolayczyk

2025 Ohio 2910
CourtOhio Court of Appeals
DecidedAugust 15, 2025
DocketS-24-022
StatusPublished
Cited by1 cases

This text of 2025 Ohio 2910 (Baber v. Mikolayczyk) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Baber v. Mikolayczyk, 2025 Ohio 2910 (Ohio Ct. App. 2025).

Opinion

[Cite as Baber v. Mikolayczyk, 2025-Ohio-2910.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT SANDUSKY COUNTY

Matthew and Tara Court of Appeals No. S-24-022 Baber Trial Court No. 23 CV 0900 Appellees

v.

Paul Mikolayczyk DECISION AND JUDGMENT

Appellant Decided: August 15, 2025

*****

Joseph D. Jakubowski, for appellees.

Thomas A. Yoder, for appellant.

OSOWIK, J.

{¶ 1} This case involves a property dispute regarding the existence and location of

an easement. The defendant-appellant, Paul Mikolayczyk, appeals an October 1, 2024

judgment by the Sandusky County Court of Common Pleas which found that the

plaintiff-appellees, Matthew and Tara Baber, own a valid and enforceable express

easement over Mikolayczyk’s property and that there are no genuine issues of material

fact as to its location. The trial court awarded the Babers $25,000 in compensatory damages for Mikolayczyk’s interference with the easement and $10,000 in punitive

damages. As set forth below, we affirm.

I. Background

{¶ 2} In 2020, the Babers acquired title to a 40-acre parcel of land (“the Baber

Parcel”) in Washington Township, Sandusky County. The Babers use their property in a

variety of ways, including for recreational purposes, harvesting wild-grown crops, and for

collecting firewood. The Babers use the firewood for their personal use and participate in

a “timber management program.”

{¶ 3} The Baber Parcel is “land-locked,” meaning that it “does not have frontage

on any road.” According to the Babers, the “only” way to access their parcel is by way

of an easement that runs through Mikolayczyk’s property, which “front[s]” County Road

87. The Babers claims that an express easement has existed in favor of the Baber Parcel

over the Mikolayczyk Parcel for more than 70 years.

{¶ 4} Mikolayczyk owns two “distinct” pieces of real estate: a 13-acre tract of

land and a “strip” of land “laying immediately south” of the 13-acre tract. The two tracts

are referred to herein as “the Mikolayczyk parcel.” Mikolayczyk purchased the property

in 2001.

2. {¶ 5} The record in this case includes a Geographic Information System (“GIS”)

map from the Sandusky County Auditor. As shown below, the map outlines the Baber

Parcel, the Mikolayczyk Parcel, and their immediate neighbors1:

A. The Creation of the Easement

{¶ 6} According to the record in this case, the Baber Parcel and the Mikolayczyk

Parcel were commonly owned between 1926 and 1949 by Emmanual Beeker. In 1949,

Beeker conveyed the Baber Parcel to James Scott through a warranty deed. The

conveyance of the Baber Parcel included an express easement over the Mikolayczyk

Parcel, which was recorded in the deed, as set forth below:

11 Both parties filed the GIS map, and they appear to be same, with the exception that Mikolayczyk’s map includes the property owners’ name and number of acres. The record discloses no objection by the Babers to Mikolayczyk’s additions, and we incorporate Mikolayczyk’s map herein.

3. Emmanual Beeker does hereby give, grant, bargain, sell and convey unto the said grantee, James F. Scott, his heirs and assigns, forever, a right of way on and over the following described lands now owned by the said grantor, to wit: - Situated in the township of Washington, Sandusky County, and State of Ohio and being a strip of land twenty-six (26) rods wide off the West side of the Northwest quarter of the Northeast quarter of Section Number Seventeen (17), in said township number five (5), Range Number Fourteen (14) East, containing thirteen (13) acres, more or less and also a strip of land one (1) rod in width and twenty-six (26) rods long East and West in the Northwest corner of the South half of Said Section Number Seventeen (17). Said last mentioned strip laying immediately South of said thirteen (13) acre tract, for the grantee, his heirs and assigns and his and their agents, servants, licensees and all other persons for the advantage of grantee, his heirs and assigns at all times to pass and repass freely on foot or with vehicles to and from the highway to the said land of the grantee, provided, however, should the said grantee, his heirs or assigns at any time sell said forty (40) acre tract of land to any adjacent or abutting land owner who has access to the highway, then this easement herein conveyed shall be null and void. The right of way hereby conveyed is to be over the driveway as now established across the thirteen (13) acre parcel and the strip one (1) rod by twenty-six (26) rods. Said driveway being approximately in the middle of the thirteen (13) acre parcel. (Emphasis added.)

{¶ 7} As a preliminary matter, we note that the original description of the

Mikolayczyk Parcel used the term “rods” to describe its dimensions and location, i.e. a

“strip of land twenty-six (26) rods wide . . . containing thirteen (13) acres more or less

and also a strip of land one (1) rod in width and twenty-six rods long.” A “rod” is a

“lineal measure of 5½ yards or 16½ feet.” Blacks Law Dictionary, Sixth Edition (1990).

It is also, according to the trial court, a “historic unit of measurement. . . which is no

longer used in modern legal descriptions.” Instead, a “metes and bounds” description is

now “generally required by current recording standards.” Id. “Metes and bounds” is “[a]

way of describing land by listing the compass directions and distances of the boundaries.”

Blacks Law Dictionary, Sixth Edition (1990). Here, the trial court determined that the

4. 2001 deed conveying the Mikolayczyk Parcel to Mikolayczyk incorporated the prior

legal description (and use of “rods”) and also included an “additional/new legal

description . . . using . . .‘metes and bounds.’” Id. The use of “rods” to describe the

Mikolayczyk Parcel is not at issue in this case, and indeed, it is well-established that

“[t]he failure to describe an easement by metes and bounds does not render the conveying

instrument invalid.” Cameron v. Mark West Liberty Midstream & Resources, LLC, 2024-

Ohio-5279, ¶ 46, quoting H & S Co., Ltd. v. Aurora, 2004-Ohio3507, ¶ 17 (11th Dist.).

B. The Babers file suit.

{¶ 8} The Babers allege in their complaint that they traversed over the easement

“largely unobstructed” from the time that they bought the property in 2020 until 2023.

However, in February of 2023, Mikolayczyk’s attorney advised them that the easement

“did not exist.” Thereafter, Mikolayczyk began to block the “entrance to the path of the

Easement,” by placing logs and other debris there, followed by increasingly larger

objects, like cement blocks, boat-trailers, a dump truck, and a “no trespassing” sign.

Mikolayczyk also threatened to press criminal trespass charges if the Babers trespassed

on his property.

{¶ 9} On October 11, 2023, the Babers filed a verified complaint, seeking a

declaratory judgment that a valid and enforceable easement exists over Mikolayczyk’s

property (Count 1) and an action in trespass for interference with their use of the

easement (Count 2). In his answer, Mikolayczyk argued that the easement had been

abandoned.

5. {¶ 10} Mikolayczyk moved for summary judgment. In his supporting affidavit,

Mikolayczyk averred that he purchased his parcel in 2001 but that he has “been involved”

with the property since 1985, when his predecessor-in-interest owned it. Mikolayczyk

acknowledged the creation of an easement in 1949. However, Mikolayczyk claimed that,

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Bluebook (online)
2025 Ohio 2910, Counsel Stack Legal Research, https://law.counselstack.com/opinion/baber-v-mikolayczyk-ohioctapp-2025.