Gettysburg Homeowners Ass'n v. Ellenburg Capital Corp.

609 N.E.2d 1315, 80 Ohio App. 3d 555, 1992 Ohio App. LEXIS 2924
CourtOhio Court of Appeals
DecidedJune 8, 1992
DocketNo. CA91-12-212.
StatusPublished
Cited by1 cases

This text of 609 N.E.2d 1315 (Gettysburg Homeowners Ass'n v. Ellenburg Capital Corp.) 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
Gettysburg Homeowners Ass'n v. Ellenburg Capital Corp., 609 N.E.2d 1315, 80 Ohio App. 3d 555, 1992 Ohio App. LEXIS 2924 (Ohio Ct. App. 1992).

Opinions

Koehler, Judge.

Plaintiff-appellant, Gettysburg Homeowners Association, appeals a decision of the Butler County Area III Court granting an application by defendantappellee, Ellenburg Capital Corporation, for release of rent payments deposited with the court.

The record indicates that appellant is an unincorporated association formed by one hundred six tenants of the Gettysburg Estates Community mobile home park in West Chester, Ohio. Appellee owns and operates the park.

On August 6, 1991, appellant sent to appellee one hundred six separate documents styled “Notice of Park Operator’s Breach of Obligation,” each relating to a lot in the park. The notices each cited thirteen Ohio Administrative Code sections that were allegedly being violated by appellee and stated that if the violations were not corrected within thirty days, the rent due for each tenant would be deposited with the court pursuant to R.C. 3733.10 and 3733.12.

No corrective action was taken within the thirty-day period and on September 6, 1991, appellant deposited the tenants’ rent with the court. On September 19, 1991, appellee filed an application for release of the deposited rent on several grounds, including insufficiency of the notices. Pending a decision on appellee’s application, appellant deposited rent payments with the court on October 6 and November 6, 1991.

A hearing on appellee’s application for release of the rent was held on October 4, 1991. On November 8, the court granted appellee’s application on the basis that the notices were not sufficiently specific to apprise appellee of the nature of the alleged violations and that, therefore, the court did not have jurisdiction to continue to hold the rent payments. Appellant brings the instant appeal, setting forth the following sole assignment of error:

“The trial court erred to the material prejudice of the appellants in finding that the Area III Court did not have jurisdiction due to the original defective notices sent by the Appellant.”

*557 Appellant argues that the notices were sufficiently specific to invoke the court’s jurisdiction to hold the escrowed rent. R.C. 3733.10, governing the obligations of a manufactured home park operator, provides in part, the following:

“(A) A park operator who is a party to a rental agreement shall:
“(1) Comply with the requirements of all applicable building, housing, health, and safety codes which materially affect health and safety and rules of the public health council;
“(2) Make all repairs and do whatever is reasonably necessary to put and keep the premises in a fit and habitable condition;
“(3) Keep all common areas of the premises in a safe and sanitary condition;
“(4) Maintain in good and safe working order and condition all electrical and plumbing fixtures and appliances, and septic systems, sanitary and storm sewers, refuse receptacles, and well and water systems that are supplied or required to be supplied by him * * *[.]”

R.C. 3733.12, addressing a resident’s remedies for an operator’s noncompliance with the obligations set forth in R.C. 3733.10, provides in part as follows:

“(A) If a park operator fails to fulfill any obligation imposed upon him by section 3733.10 of the Revised Code or by the rental agreement, or the conditions of the premises are such that the resident reasonably believes that a park operator has failed to fulfill any such obligations, or a governmental agency has found that the premises are not in compliance with building, housing, health, or safety codes which apply to any condition of the residential premises that could materially affect the health and safety of an occupant, the resident may give notice in writing to the park operator specifying the acts, omissions, or code violations that constitute noncompliance with such provisions. The notice shall be sent to the person or place where rent is normally paid.
“(B) If a park operator receives the notice described in division (A) of this section and after receipt of the notice fails to remedy the condition within a reasonable time, considering the severity of the condition and the time necessary to remedy such condition, or within thirty days, whichever is sooner, and if the resident is current in rent payments due under the rental agreement, the resident may do one of the following:
“(1) Deposit all rent that is due and thereafter becomes due the park operator with the clerk of court of the municipal or county court having jurisdiction in the territory in which the residential premises are located * * *r

*558 Finally, R.C. 3733.122, governing application for release of rent, states, in part, the following:

“(A) A park operator who receives notice that rent due him has been deposited with a clerk of court pursuant to section 3733.12 of the Revised Code, may:
U * * *
“(2) Apply to the court for release of the rent on the grounds that the resident did not comply with the notice requirement of division (A) of section 3733.12 of the Revised Code, or that the resident was not current in rent payments due under the rental agreement at the time the resident initiated rent deposits with the clerk of courts under division (B)(1) of section 3733.12 of the Revised Code * * *[.]”

Thus, the statutory scheme contemplates notice sufficiently specific to enable the park operator to discern the nature of the alleged problem and to remedy the problem within a reasonable period of time. R.C. 3733.12. The provisions of R.C. 3733.12(A) have been construed to require notice of “specific instances” of the park operator’s failure to fulfill its statutory obligations as a prerequisite to the court being able to continue to hold the deposited rent. R.C. 3733.12(A); Woodlake Assn. v. Heringhausen (Jan. 18,1991), Wood App. No. WD-89-27, unreported, 1991 WL 3810.

In the instant case, the trial court did not err in finding the notices sent by appellant to be insufficiently specific. The notices contained no specific instances of acts or omissions that allegedly constituted violations of appellee’s statutory duties. Instead, appellant merely cited numerous sections of the Ohio Administrative Code as asserted violations.

Appellant argues that these citations were sufficient to apprise appellee of the alleged violations. We do not find this argument to be persuasive. While the citations may have informed appellee of the general nature of the alleged violation, they did not give any indication of the specific problems such as to enable appellee to remedy them. For example, appellant cited Ohio Adm.Code 3701-27-24 as one of the claimed violations. That section provides the following:

“(A) Electrical systems in mobile home parks shall be installed and maintained in accordance with applicable provisions of the national electric code, local electrical codes and the approved plans.

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Bluebook (online)
609 N.E.2d 1315, 80 Ohio App. 3d 555, 1992 Ohio App. LEXIS 2924, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gettysburg-homeowners-assn-v-ellenburg-capital-corp-ohioctapp-1992.