Barker v. McCoy

2015 Ohio 3127
CourtOhio Court of Appeals
DecidedJuly 29, 2015
Docket14CA849
StatusPublished
Cited by1 cases

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Bluebook
Barker v. McCoy, 2015 Ohio 3127 (Ohio Ct. App. 2015).

Opinion

[Cite as Barker v. McCoy, 2015-Ohio-3127.]

IN THE COURT OF APPEALS OF OHIO FOURTH APPELLATE DISTRICT PIKE COUNTY

James Barker, et al., : Case No. 14CA849

Plaintiffs-Appellees, :

v. : DECISION AND JUDGMENT ENTRY Dale McCoy, et al., :

Defendants-Appellants. : RELEASED: 7/29/2015

APPEARANCES:

Thomas M. Spetnagel, Chillicothe, Ohio, for appellants.

J.B. Marshall, Jr., Portsmouth, Ohio, for appellees.

Harsha, J. {¶1} James, Paul and Viola Barker filed a complaint against Dale and Robert

McCoy to quiet title to 50 acres of land in Pike County and seeking damages for theft of

timber. McCoys counterclaimed to quiet title, alleging that they were the fee simple

owners of the disputed 50 acres. Later both sides amended their claims to include

allegations of ownership through adverse possession. After a bench trial the court ruled

in favor of the Barkers and awarded them compensatory and punitive damages, as well

as attorney fees.

{¶2} The McCoys assert that the trial court erred when it quieted title to the

disputed property to the Barkers. The McCoys argue that because the Barkers’ surveyor

failed to follow the applicable standards for determining property boundaries, the trial

court erred as a matter of law in considering the survey. The McCoys argue that without

the survey the trial court’s decision is against the manifest weight of the evidence. To Pike App. No. 14CA849 2

the extent the McCoys argue that the survey should not have been admitted into

evidence, they forfeited this argument because they offered no objection to it at trial.

And based on the survey there is substantial competent, credible evidence that the

Barkers owned the 50 acres by virtue of their deed. Accordingly, we overrule the

McCoys’ first assignment of error.

{¶3} Next the McCoys claim that the trial court erred when it permitted the

Barkers to amend their pleading to conform to the evidence to assert ownership of the

property through adverse possession, and that the court further erred in ruling in the

Barkers’ favor on that claim. Because we affirm the trial court’s finding that the Barkers

were the legal titleholders of the disputed property by deed, this assignment of error is

moot.

{¶4} The McCoys’ remaining claims concern the court’s damages award. First,

they contend that there was insufficient evidence to find Robert McCoy individually

liable to the Barkers. However, the record contains substantial competent, credible

evidence of Robert McCoy’s personal involvement in the trespass and tree removal

operation. Therefore, we affirm the trial court’s award of damages against Robert

McCoy, individually. Additionally the record contains competent credible evidence that

Robert McCoy’s conduct was characterized by ill will, a spirit of revenge, and a

conscious disregard for the rights of the Barkers. Therefore, the trial court properly

assessed punitive damages. However, there was no evidence in the record of the

reasonableness of the attorney fees awarded, thus the trial court abused its discretion in

awarding them. We overrule the McCoys’ fourth and fifth assignments of error Pike App. No. 14CA849 3

concerning Robert McCoy’s individual liability and punitive damages, but find merit in

the McCoys’ sixth assignment of error concerning the attorney fees award.

I. FACTS

{¶5} James, Paul and Viola Barker claim ownership of a 50 acre tract of land in

Pike County, Ohio.1 They assert that James’s father, Floyd Barker, received title to the

land by deed in 1942. The 50 acre tract, which is one of four contiguous parcels owned

by the Barkers, is the only one involved in the dispute. Dale McCoy and his brother

Robert McCoy own a 90 acre tract of land contiguous to the disputed 50 acre tract,

which they also claimed to own. The dispute reached full bloom in late 2001 and early

2002. The Barkers testified that they were considering selling their entire holdings and

had the property surveyed. Dale and Robert McCoy believed that 50 acres belonged to

them and disagreed with the Barkers’ survey. The McCoys decided to commence

harvesting timber on the 50 acres despite the ongoing dispute. The Barkers filed a

lawsuit and sought a preliminary injunction against the McCoys to prevent them from

continuing their timber harvesting operations pending a court decision to determine

ownership of the 50 acres. The trial court granted the Barkers a preliminary injunction

and ultimately awarded them ownership of the 50 acres, compensatory damages

including attorney fees, and punitive damages. The McCoys appealed.

II. ASSIGNMENTS OF ERROR

{¶6} The McCoys assign the following errors for our review:

1. The Trial Court Erred In Quieting Title to the Disputed Property in Favor of Appellees.

1 The parties refer to the acreage interchangeably as 49.5 acres and 50 acres. Subsequent surveys have calculated the acreage to be 53.4454 acres. For consistency, we refer to it as 50 acres. Pike App. No. 14CA849 4

2. The Trial Court Erred In Permitting Appellees to Amend Their Pleadings to Conform to the Evidence.

3. The Trial Court Erred In Finding in Favor of Appellees on Their Claim for Adverse Possession.

4. The Trial Court Erred In Awarding Damages Against Appellee Robert McCoy, Individually.

5. The Trial Court Erred In Awarding Punitive Damages to Appellees.

6. The Trial Court Erred In Making an Award of Attorney Fees to Appellees.

III. LAW AND ANALYSIS

A. The Evidence Supports Quieting Title by deed in Favor of the Barkers

{¶7} In arguing it was error to quiet title in favor of the Barkers, the McCoys

contend that the trial court improperly relied upon the Barkers’ survey evidence because

their surveyor, Hubert M. Crabtree, failed to follow the applicable standards for

boundary surveys. They argue that the Ohio State Board of Registration for

Professional Engineers and Surveyors has established minimum standards for

boundary surveys and that the evidence shows that the Barkers’ surveyor failed to

follow the acceptable principles for resurveying boundary lines. They contend that the

trial court erred as a matter of law in relying on this survey; and without the contested

survey, they further contend the court’s decision to award the property to the Barkers

was against the manifest weight of the evidence.

{¶8} The McCoys argue that they are not challenging the weight given by the

trial court to the survey, but rather its admissibility as competent evidence (“the Pike App. No. 14CA849 5

dispositive issue does not concern the weight given by the trial court to Appellees’

survey, rather the issue is whether the court erred as a matter of law in considering that

evidence…”). However, in spite of arguing now that the survey should not have been

admitted, they offered no objection to it at trial. The record contains several survey

exhibits, some of which are survey maps prepared by Crabtree. The McCoys stipulated

to Crabtree’s qualifications as an expert witness and did not object to the admission of

any of the survey exhibits prepared by Crabtree. The trial court adopted the legal

description and plat prepared by Crabtree in its decision, attaching a copy as Exhibit A

to the judgment entry.

{¶9} A party forfeits any error that arises during the trial court proceedings if

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