Chase Home Fin., L.L.C. v. Keys

2016 Ohio 17
CourtOhio Court of Appeals
DecidedJanuary 7, 2016
Docket102045
StatusPublished

This text of 2016 Ohio 17 (Chase Home Fin., L.L.C. v. Keys) 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
Chase Home Fin., L.L.C. v. Keys, 2016 Ohio 17 (Ohio Ct. App. 2016).

Opinion

[Cite as Chase Home Fin., L.L.C. v. Keys, 2016-Ohio-17.]

Court of Appeals of Ohio EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

JOURNAL ENTRY AND OPINION No. 102045

CHASE HOME FINANCE, L.L.C. PLAINTIFF-APPELLEE

vs.

MICHELLE KEYS, INDIVIDUALLY, ETC., ET AL., DEFENDANTS-APPELLANTS

JUDGMENT: VACATED

Civil Appeal from the Cuyahoga County Court of Common Pleas Case No. CV-10-737885

BEFORE: Blackmon, J., E.T. Gallagher, P.J., and Stewart, J.

RELEASED AND JOURNALIZED: January 7, 2016 ATTORNEYS FOR APPELLANTS

David A. Schaeffer Danielle G. Garson McCarthy Lebit Crystal & Liffman Company 101 West Prospect Avenue 1800 Midland Building Cleveland, Ohio 44115

ATTORNEYS FOR APPELLEE

Bill L. Purtell Cynthia Fischer Lerner, Sampson & Rothfuss 120 E. 4th Street Suite 800 Cincinnati, Ohio 45202

Stacy L. Hart Susan E. Mandryk Lerner, Sampson & Rothfuss P.O. Box 5480 Cincinnati, Ohio 45201 PATRICIA ANN BLACKMON, J.:

{¶1} Defendant-appellants Michelle Keys (Keys), individually and as

administrator of the estate of Dolores Thomas (Thomas), et al., appeal the trial court’s

denial of Keys’s motion to enforce a settlement agreement against plaintiff-appellee

Chase Home Finance, L.L.C. (Chase). Keys assigns two errors for our review, which

will be addressed together.

I. The trial court erred as a matter of law when it denied Mr. and Ms. Keys’s motion to enforce the settlement agreement.

II. The trial court abused its discretion when it ignored the unrebutted evidence and denied Mr. and Ms. Keys’s motion to enforce the settlement agreement.

{¶2} Having reviewed the record and pertinent law, we vacate the trial court’s

ruling for lack of jurisdiction. The apposite facts follow.

Facts and Procedural History

{¶3} The dispute between the parties to this case began in 2008, when Chase

filed two foreclosure actions on two residential properties owned by Thomas. In 2009,

the parties entered a forbearance agreement. In 2010, Thomas passed away, and title to

the properties was transferred to Keys. Chase subsequently pursued foreclosure of the

properties against Keys.

{¶4} The issue before this court specifically concerns another forbearance

agreement that Chase and Keys entered into in June 2011. Keys agreed to make five

monthly payments of $385 each, and Chase agreed to postpone foreclosure proceedings on one of the properties at issue located in Cleveland Heights. As a result of this

forbearance agreement, and per the trial court’s standing case management directive,

Chase’s claims against Keys were dismissed without prejudice on July 14, 2011, and

Keys dismissed her counterclaim against Chase without prejudice on July 26, 2011.

{¶5} On April 22, 2013, Keys filed a motion to enforce the settlement agreement,

arguing that Chase refused to honor an alleged oral modification to the forbearance

agreement. Specifically, Keys argued that immediately after the terms of the forbearance

agreement were memorialized in writing, counsel for the parties had a conversation near

the 10th floor elevators of the Justice Center (the Elevator Conversation), in which

counsel for Chase “expressed to both defense counsel that if Mrs. Keys made the five

forbearance payments in a timely manner, that * * * the lender would agree to execute a

Loan Modification and/or Assumption.”

{¶6} The court denied Keys’s motion to enforce the settlement agreement on

jurisdictional grounds on April 24, 2013. Keys appealed, and this court found that the

trial court retained jurisdiction, reversed the trial court’s ruling, and remanded the case to

hold “an evidentiary hearing to determine if an enforceable settlement exists.” Chase

Home Finance, L.L.C. v. Keys, 8th Dist. Cuyahoga No. 99920, 2014-Ohio-2639, (Keys I).

On remand, the trial court held an evidentiary hearing, and on September 19, 2014, the

court denied Keys’s motion to enforce settlement agreement, finding that Keys failed to

show, by a preponderance of the evidence, that the Elevator Conversation was an enforceable modification to the forbearance agreement. It is from this order that Keys

appeals.

Standard of Review

{¶7} We address Keys’s allegations of error together under a mixed standard of

review. Compare Continental W. Condo. Unit Owners Assn v. Howard E. Ferguson,

Inc., 74 Ohio St.3d 501, 502, 660 N.E.2d 431 (1996) (when the issue regarding a motion

to enforce settlement agreement “is a question of contract law, Ohio appellate courts must

determine whether the trial court’s order is based on an erroneous standard or

misconstruction of the law”) with Tabbaa v. Koglman, 8th Dist. Cuyahoga No. 84539,

2005-Ohio-1498, ¶ 15 (“[b]ecause the instant case involves factual determinations by the

trial court as to the parties’ intent surrounding a settlement agreement, * * * the

applicable standard of review is an abuse of discretion * * *”).

Whether the Oral Modification to the Forbearance Agreement Is Enforceable

{¶8} A settlement agreement falls within the purview of contract law and

requires an offer, acceptance, consideration, and a meeting of the minds to be binding.

Prime Properties, Ltd. Partnership v. Badah Ents., 8th Dist. Cuyahoga No. 99827,

2014-Ohio-206. “[A]n oral settlement agreement may be enforceable if there is

sufficient particularity to form a binding contract. Terms of an oral contract may be

determined from ‘words, deeds, acts, and silence of the parties.’” Id. at ¶ 8, quoting

Kostelnik v. Helper, 96 Ohio St.3d 1, 3, 2002-Ohio-2985, 770 N.E.2d 58. {¶9} A forbearance agreement is “a separate and distinct contract from the original

mortgage [and] is, therefore, no different than other settlement agreements.” First

Horizon Home Loans v. Mohsen Fanous, 8th Dist. Cuyahoga No. 95924,

2011-Ohio-4237, ¶ 9. A forbearance is “a delay in enforcing * * * debts, rights of action,

rights, privileges, claims or obligations.” (Citation omitted.) HomEq Servicing Corp. v.

Schwamberger, 4th Dist. Scioto No. 07CA3146, 2008-Ohio-2478, ¶ 19. Forbearance

means “[r]efraining from doing something that one has a legal right to do.” Black’s Law

Dictionary 644 (6th Ed.1990).

{¶10} The forbearance agreement in the instant case states that Chase would

postpone foreclosure proceedings if Keys made five monthly payments of $385 from

August 1 through December 1, 2011. Other than postponing foreclosure proceedings,

Chase retained its legal rights and remedies to pursue a foreclosure action against Keys.

The forbearance agreement at issue expressly states, in pertinent part, as follows:

The payments required in this Agreement to postpone foreclosure proceedings may not be sufficient to satisfy the regular monthly payments required by the loan documents. Therefore it is likely that the loan will still be in default after [Keys] makes all payments required by this Agreement. * * * [Keys] acknowledges that this Agreement may not cure the default. * * * Except as provided in this Agreement, the terms of the original note, mortgage/deed of trust and other loan documents remain in full force and effect. * * * This Agreement cannot be amended without the written consent of both parties.

{¶11} Despite agreeing to these terms, Keys argues that the Elevator Conversation

is an enforceable modification to the forbearance agreement, which Chase allegedly

breached by pursuing foreclosure.

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Related

Chase Home Fin., L.L.C. v. Keys
2014 Ohio 2639 (Ohio Court of Appeals, 2014)
Prime Properties Ltd. Partnership v. Badah Ents.
2014 Ohio 206 (Ohio Court of Appeals, 2014)
First Horizon Home Loans v. Fanous
2011 Ohio 4237 (Ohio Court of Appeals, 2011)
Ott Equip. Servs., Inc. v. Summit Automotive Equip.
2015 Ohio 4263 (Ohio Court of Appeals, 2015)
Homeq Servicing Corp. v. Schwamberger, 07ca3146 (5-20-2008)
2008 Ohio 2478 (Ohio Court of Appeals, 2008)
Tabbaa v. Koglman, Unpublished Decision (3-31-2005)
2005 Ohio 1498 (Ohio Court of Appeals, 2005)
Kostelnik v. Helper
96 Ohio St. 3d 1 (Ohio Supreme Court, 2002)
Pratts v. Hurley
102 Ohio St. 3d 81 (Ohio Supreme Court, 2004)
Kostelnik v. Helper
2002 Ohio 2985 (Ohio Supreme Court, 2002)

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2016 Ohio 17, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chase-home-fin-llc-v-keys-ohioctapp-2016.