Harding v. Ohio Real Estate Comm.

2023 Ohio 3138, 224 N.E.3d 86
CourtOhio Court of Appeals
DecidedSeptember 1, 2023
DocketL-23-1010
StatusPublished
Cited by1 cases

This text of 2023 Ohio 3138 (Harding v. Ohio Real Estate Comm.) 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
Harding v. Ohio Real Estate Comm., 2023 Ohio 3138, 224 N.E.3d 86 (Ohio Ct. App. 2023).

Opinion

[Cite as Harding v. Ohio Real Estate Comm., 2023-Ohio-3138.]

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

Angela Harding Court of Appeals No. L-23-1010

Appellant Trial Court No. CI0202203138

v.

Ohio Real Estate Commission DECISION AND JUDGMENT

Appellee Decided: September 1, 2023

*****

David L. Petitjean, for appellant

David Yost, Ohio Attorney General and Elizabeth S. Fligner, Senior Assistant Attorney General, for appellant.

***** MAYLE, J.

{¶ 1} Appellant, Angela F. Harding, appeals from a judgment of the Lucas County

Court of Common Pleas affirming an adjudication order by appellee, the Ohio Real

Estate Commission (“OREC”), that found Harding violated Chapter 4735 of the Ohio

Revised Code. We affirm. I. Background

{¶ 2} Harding holds a real estate broker’s license with the Ohio Department of

Commerce, Division of Real Estate and Professional Licensing (“the Division”).

{¶ 3} In October of 2013, Harding entered into a land contract with Breck

Properties Ltd. for the purchase of property located at 5012 Maryhill Road in Sylvania,

Ohio. Kathryn Long is the sole shareholder of Breck Properties. The property was

intended to serve as Harding’s primary residence.

{¶ 4} The purchase price of the property was $113,900, and Harding paid Long an

initial down payment of $7,500. Under the terms of the land contract, Harding was

required to pay the balance of $106,400 at seven percent interest over 30 years, through a

monthly payment of $707.88. Upon payment in full of all sums owed, Long, acting on

behalf of Breck Properties, agreed to deliver to Harding “a good and sufficient warranty

deed conveying title to the land.”

{¶ 5} On November 7, 2016, Long filed a complaint against Harding with the

Division. Long alleged that Harding had listed the property for sale without her consent,

in violation of real estate licensing laws and the land contract.

{¶ 6} Following an investigation, the Division sent Harding a notification that it

had found “reasonable and substantial evidence of acts” in violation of R.C. 4735.18

(“Grounds for suspension or revocation of license”) and that, if the violations were

proven, disciplinary action could be taken against Harding’s license. Specifically, the

complaint alleged that,

2. You, Angela Faye Harding, a licensed principal real estate broker *

* * did the following sometime between on or about June 26, 2016 and on

or about July 11, 2016, involving the property at 5012 Maryhill Road,

Sylvania, Ohio (subject property):

Despite entering into a land contract for the subject property, dated

October 25, 2013 (land contract), as a buyer, which specifically prohibited

the transfer of your interest in the land contract to another party without

prior written consent by Breck Properties, Ltd. (seller), you attempted to

sell the subject property with a sign in the subject property’s yard or

through an advertisement in the multiple listing service with [listing agent]

* * *, without prior written consent of the seller. This conduct constitutes a

violation of Ohio Revised Code Section 4735.18(A)(17) or Ohio Revised

Code Section 4735.18(A)(6), misconduct as that section incorporates

Section, Article I of the Canons of Ethics for the Real Estate Industry, a

failure to maintain high standards of conduct in a licensee’s personal

affairs.

{¶ 7} A hearing was held before a hearing examiner on July 30, 2021. Three

witnesses testified: Investigator George Burton, Long, and Harding.

{¶ 8} According to Long, Harding asked her, in June of 2016, if she (Harding)

could “list the property and sell it.” When asked what she would do with any profits

from the sale, Harding said that she would pay off the remaining balance owed to Long

3. and “keep” the rest. Long told Harding that she could “[a]bsolutely not” list the property

because “[i]t wasn’t hers to sell.”

{¶ 9} The conversation caused Long to “wonder * * * what [Harding] was up to.”

And so, about a week later, in July, “[Long] drove past the house” and saw a real estate

sign in the yard. Long’s testimony on this point conflicted with her previous claim,

made in her “Real Estate Complaint Form,” in which she specified that she “looked up

[the] property on line and found [that Harding had] listed it.” According to the

complaint, Long “sent [her] husband to the property to verify if there was a sign in the

yard and he took a picture.” (Emphasis added.)

{¶ 10} In any event, the listing agent identified on the yard sign was Sarah Ford of

Key Realty. Long went “directly to the real estate agen[cy]” and told someone there, “I

own [the property] myself.” Long was told that Harding had taken the property “off the

market as of June 29th,” notwithstanding that the sign remained in the yard. Long

demanded that the agency “get that sign out of my yard” and gave them “til noon.” Later

that day, a broker with Key Realty called Long to apologize and reported that “they were

duped as well.”

{¶ 11} During Harding’s testimony, she denied having a conversation with Long,

or asking for permission from her to list the property. Harding testified that, before

listing it, she consulted with her attorney, who explained that she had an “equitable

interest” in the property and “because [she] had an equitable interest,” she did not need

Long’s permission to list it. Harding also understood that her right to “transfer interest”

4. in the property to a third party was subject to Long being “paid off [first] * * * which

would be done at closing.” Before listing the property, Key Realty “review[ed] all the

documentation.”

{¶ 12} The listing with Key was in effect from June 28, 2016 until July 11, 2016,

when Harding “pull[ed] the listing.” Harding explained that she pulled the listing

because it was “an overwhelming time” in her life. “Shortly after” that, Harding learned

from Key Realty that Long had complained about the sign, but Long never personally

contacted her to discuss it. Harding testified that she believes she “acted with full ethics

from the beginning of this transaction to the end, including [when she] list[ed] the

property.”

{¶ 13} Harding and her husband decided to terminate the land contract and return

the property to Long. On November 2, 2016, the parties executed a “Cancelation of Land

Contract” and a mutual release. Five days later, on November 7, 2016, Long filed a

complaint against Harding, giving rise to the instant case.

II. The Report and Recommendation of the Hearing Officer

{¶ 14} The hearing examiner issued a Report and Recommendation on October

13, 2021, which included the following findings of fact and conclusions of law:

Both Harding and Long had an ownership interest in the property,

Harding as “equitable owner” and Long as “legal owner.”

5. Harding entered into a listing agreement with Realtor Sarah Ford, of

Key Realty, to sell the Maryhill property, and a “for sale” sign was placed

on the property. The listing date was June 28, 2016.

Harding, as an equitable owner, did not transfer any interest or title in

the subject property by entering into the listing agreement with Key Realty.

The listing agreement gave no equitable interest in the land contract or the

property. “The act of entering into [the Exclusive Right to Sell Listing]

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Cite This Page — Counsel Stack

Bluebook (online)
2023 Ohio 3138, 224 N.E.3d 86, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harding-v-ohio-real-estate-comm-ohioctapp-2023.