Berning v. Lutheran Hous. Serv. 9

2024 Ohio 1173, 241 N.E.3d 816
CourtOhio Court of Appeals
DecidedMarch 28, 2024
DocketL-22-1281
StatusPublished
Cited by1 cases

This text of 2024 Ohio 1173 (Berning v. Lutheran Hous. Serv. 9) 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
Berning v. Lutheran Hous. Serv. 9, 2024 Ohio 1173, 241 N.E.3d 816 (Ohio Ct. App. 2024).

Opinion

[Cite as Berning v. Lutheran Hous. Serv. #9, 2024-Ohio-1173.]

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

Carol Berning, Executrix of the Court of Appeals No. L-22-1281 Estate of Mary H. Kohn, et al. Trial Court No. CI0201902468 Appellees

v.

Lutheran Housing Service #9, DECISION AND JUDGMENT et al., Decided: March 28, 2024 Appellees

*****

Brian P. O’Connor, Charles E. Reynolds, and Michael S. Spillane, for appellees.

Joseph F. Petros, III and Christopher G. Kuhn for appellants.

ZMUDA, J.

I. Introduction

{¶ 1} Appellants, Lutheran Housing Service #9 and Lutheran Home Society, Inc.,

appeal the November 1, 2022, judgment of the Lucas County Court of Common Pleas

granting summary judgment in favor of appellees, Mary Kohn, represented by Carol Berning as executrix of her estate; Sharon Vaughn; and Harry Wagner, represented by

Kathy Schwartz as executrix of his estate. For the following reasons, we reverse the trial

court’s judgment and grant summary judgment in favor of appellants.

A. Facts and Procedural Background

{¶ 2} The facts of this case are largely undisputed. Each appellee previously

entered into their own separate contract with appellants. While the specific terms of the

three agreements differ—for example, the amount paid by each appellee—the terms

relevant to this appeal were common among all three agreements. Each contract was for

the purchase of a life lease in a residential unit in one of appellants’ condominium

complexes in Lucas County, Ohio. The basic terms of the agreements were that each

appellee paid a certain amount of money for the right to live in the unit for the rest of

their lives with no further rent obligations beyond that initial payment. The leases

required each appellee to pay a monthly “Maintenance Fee” in exchange for appellants

providing certain services at the complex and to cover payment of any real estate taxes

apportioned to their individual units. Upon termination of the leases, either by an

appellees’ death or for other reasons authorized under the leases, that appellee was

entitled to a refund of some portion of that initial purchase price when a new tenant

purchased a lease in the vacated unit. At some point prior to this litigation, each appellee

terminated their lease agreement. Upon termination, the parties disagreed as to whether

the purchase price should be construed as a security deposit subject to return to appellees

pursuant to R.C. 5321.16. When appellants refused to return the purchase price upon

2. termination of the lease, each appellee filed a complaint in the Lucas County Court of

Common Pleas.

{¶ 3} Appellee Berning, acting as executrix for Mary Kohn, filed her complaint on

May 16, 2019. Appellee Vaughn then filed her complaint against appellants on May 23,

2019. Kathy Schwartz, acting as executrix of Harry Wagner’s estate, filed her complaint

against appellants on July 12, 2019. The complaints were ultimately consolidated

pursuant to Civ.R. 42. As to their enumerated claims for relief, each appellee alleged that

appellants violated R.C. 5321.16(A) by failing to pay interest on a security deposit made

by appellees, violated R.C. 5321.16(C) by failing to return the security deposit within 30

days of termination of the lease, committed deceptive or unconscionable acts in violation

of R.C. 1345.02 to 1345.04—Ohio’s Consumer Sales Practices Act, unjust enrichment,

and that appellants engaged in a civil conspiracy to defraud appellees. Each appellee also

sought a declaratory judgment finding that certain terms of the parties’ lease agreements

were unconscionable.

{¶ 4} The complaints specifically allege that the life lease purchase prices were

actually security deposits, as described by R.C. 5321.01(E), which defines a “security

deposit” as “any deposit of money or property to secure performance by the tenant under

a rental agreement.” Appellees alleged that the purchase price was intended to “secure

the condition of the property at the conclusion of her tenancy and to secure the monthly

fees due and owing [appellants] pursuant to [their] lease.” In light of this allegation,

appellees claimed that appellants were obligated to return the entire purchase price of

3. their life leases as a security deposit, pursuant to R.C. 5321.16, within 30 days of

termination of the lease. Prior to filing their complaints, each appellee demanded return

of the purchase price for their own life lease. Appellants declined the demands.

{¶ 5} On July 19, 2021, appellants filed a motion for summary judgment as to all

of appellees’ claims. Appellees filed a joint motion for partial summary judgment as to

their security deposit-related claims only that same day. Relevant to the security deposit-

related claims, appellants argued that the purchase price was the consideration for the life

leases only and did not secure appellees’ performance of any of their obligations under

the agreements. Conversely, in their motion for partial summary judgment, appellees

sought an order finding, as a matter of law, that the purchase price constituted a security

deposit subject to the terms of R.C. 5321.16. Specifically, appellees argued that because

the term of the agreements mandating a refund of a specified percentage of the selling

price of a life lease in the unit to a subsequent purchaser could be reduced to reflect any

debts owed to appellants, that the purchase price served as a security deposit as defined

by R.C. 5321.01(E).

{¶ 6} On May 5, 2022, the trial court denied appellants’ motion for summary

judgment as to appellees’ security deposit-related claims and granted appellees’ motion

for partial summary judgment. In its order, the trial court determined that the language of

the parties’ agreements was clear in that it reflected their intent for the purchase price to

serve as consideration for the life lease. However, the court held that this language alone

was not controlling on the issue before it because R.C. 5321.13(A) prohibits landlords

4. from contracting away duties prescribed in R.C. Chapter 5321. That is, if the purchase

price was in fact a security deposit, the parties’ agreements defining it otherwise to

permit appellants to avoid returning the deposit as required by R.C. 5321.16 would

violate R.C. 5321.13(A).

{¶ 7} The court then noted that the “primary substantive” issue before it was

whether the purchase price qualified as a security deposit. Finding that this was a case of

first impression, the trial court provided a framework through which it would reach this

determination, stating:

the Court examines whether the property interests/rights Plaintiffs acquired by contracting with Defendants more closely resemble those in a residential lease or those in the purchase of real estate. If the transactions more closely resemble a lease, the Court will find Plaintiff’s purchase price deposits constituted security deposits. By contrast, if the transactions more closely resemble the purchase of real estate, the court will uphold the contracts as written.

After performing this analysis, the trial court determined that the agreements did not

grant appellees any property rights in the units normally associated with the purchase of

real estate—that is, appellees had no equity in the unit itself, they could not borrow

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2024 Ohio 1173, 241 N.E.3d 816, Counsel Stack Legal Research, https://law.counselstack.com/opinion/berning-v-lutheran-hous-serv-9-ohioctapp-2024.