Kneebusch v. Kneebusch

CourtOhio Court of Appeals
DecidedMay 11, 2026
Docket2025CA0045-M
StatusPublished

This text of Kneebusch v. Kneebusch (Kneebusch v. Kneebusch) 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
Kneebusch v. Kneebusch, (Ohio Ct. App. 2026).

Opinion

[Cite as Kneebusch v. Kneebusch, 2026-Ohio-1705.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF MEDINA )

JANET KNEEBUSCH C.A. No. 2025CA0045-M

Appellee

v. APPEAL FROM JUDGMENT ENTERED IN THE JEREMY KNEEBUSCH COURT OF COMMON PLEAS COUNTY OF MEDINA, OHIO Appellant CASE No. 2023CIV081

DECISION AND JOURNAL ENTRY

Dated: May 11, 2026

SUTTON, Judge.

{¶1} Appellant Jeremy Kneebusch appeals the judgment of the Medina County Court of

Common Pleas. For the reasons that follow, this Court reverses and remands for further

proceedings.

I.

Relevant Background

{¶2} This appeal arises from Mr. Kneebusch’s 2013 purchase of real property located in

Medina, Ohio. At that time, Mr. Kneebusch’s parents, Janet Kneebusch, and Jeffrey Kneebusch

now deceased, were undergoing financial difficulties and could not secure a mortgage to purchase

a home. Mr. Kneebusch secured the mortgage note in his name and his parents lived in the home.

Mrs. Kneebusch and her husband provided the downpayment for the purchase of the home and

paid the principal, interest, escrow, and other expenses of upkeep and maintenance on the home.

The Warranty Deed for the property is in Mr. Kneebusch’s name alone. {¶3} On November 7, 2023, Mrs. Kneebusch filed a complaint against her son alleging

his refusal to transfer title to the property to her name. The complaint alleged two counts: (1)

anticipatory breach of an oral agreement; and (2) unjust enrichment. Mr. Kneebusch filed an

answer and counterclaim. In his counterclaim, Mr. Kneebusch alleged three claims for relief and

asked the trial court: (1) to quiet title to the property as he is the sole, fee simple owner of the

property; (2) to declare his interests in the property are superior to those of Mrs. Kneebusch and

declare Mrs. Kneebusch’s interest in the property is void or voidable; and (3) to award him

damages based upon the theories of unjust enrichment and quantum meruit.

{¶4} Subsequent to a period of discovery, Mrs. Kneebusch filed a motion for summary

judgment against Mr. Kneebusch on her complaint and his counterclaim. In her motion, Mrs.

Kneebusch argued: (1) the property is held in a resulting trust by Mr. Kneebusch for the benefit of

Mrs. Kneebusch; and (2) even if a resulting trust did not exist, a constructive trust should be

imposed because Mr. Kneebusch would be unjustly enriched as a result of being able to retain title

to the property.

{¶5} Mr. Kneebusch filed a response in opposition to Mrs. Kneebusch’s motion for

summary judgment alleging there are two versions of events which may have transpired at the time

Mr. Kneebusch purchased the property. Mr. Kneebusch alleged, prior to purchasing the property,

he and his father had conversations that Mrs. Kneebusch was not a party to, wherein his father

asked Mr. Kneebusch to purchase the property to be his and Mrs. Kneebusch’s primary residence,

for which they would pay the mortgage, utilities, insurance, and taxes, in lieu of monthly rent to

Mr. Kneebusch. In exchange for this agreement, Mr. Kneebusch would own the property and hold

it as a long-term investment that he could sell for a future gain. Mr. Kneebusch denied Mrs.

Kneebusch’s argument that he bought the property “out of the goodness of his heart[.]” Mr. Kneebusch further argued any anticipatory breach of an oral contract was barred by the statute of

frauds and there were genuine issues of material fact relating to whether a resulting or constructive

trust was created to benefit Mrs. Kneebusch.

{¶6} The trial court issued a judgment entry granting Mrs. Kneebusch’s motion for

summary judgment. In citing Civ.R. 56(C), the trial court indicated, in relevant part, it,

“considered all of the evidence” and “construed the evidence in this matter in a light most favorable

to [] [Mr. Kneebusch[.]” In so doing, the trial court determined “that reasonable minds can come

but to one conclusion, that there are no genuine issues of material fact and that [] [Mrs. Kneebusch]

is entitled to judgment as a matter of law.” The trial court then ordered, without any analysis:

1. [Mr. Kneebusch] is decreed to be the trustee of the property [] and holds the [p]roperty for the benefit of [Mrs. Kneebusch].

2. [Mr. Kneebusch] convey fee simple title of the [p]roperty to [Mrs. Kneebusch] within [30] days of payment of the [n]ote dated March 18, 2013[,] in full.

3. [Mr. Kneebusch’s [c]ounterclaim is dismissed in its entirety.

{¶7} Mr. Kneebusch appealed raising three assignments of error for our review.

ASSIGNMENT OF ERROR I

THE TRIAL COURT’S SUMMARY JUDGMENT ENTRY LACKS SUFFICIENT DETAIL TO FACILITATE APPELLATE REVIEW.

{¶8} In his first assignment of error, Mr. Kneebusch argues the trial court’s summary

judgment entry lacks sufficient detail to facilitate appellate review. For the following reasons, we

agree.

{¶9} Pursuant to Civ.R. 56(C), summary judgment is appropriate when: (1) no genuine

issue as to any material fact exists; (2) the party moving for summary judgment is entitled to

judgment as a matter of law; and (3) viewing the evidence most strongly in favor of the nonmoving party, reasonable minds can only reach one conclusion, and that conclusion is adverse to the

nonmoving party. Temple v. Wean United, Inc., 50 Ohio St.2d 317, 327 (1977). To succeed on a

motion for summary judgment, the moving party bears the initial burden of demonstrating the

absence of genuine issues of material fact concerning the essential elements of the nonmoving

party’s case. Dresher v. Burt, 75 Ohio St.3d 280, 292 (1996). Specifically, the moving party must

support the motion by pointing to some evidence in the record of the type listed in Civ.R. 56(C).

Id. at 292-293. Once the moving party satisfies this burden, the nonmoving party has a “reciprocal

burden” to “‘set forth specific facts showing that there is a genuine issue for trial.’” Id. at 293,

quoting Civ.R. 56(E)

{¶10} Here, the trial court’s entry granting summary judgment in favor of Mrs. Kneebusch

contains one reference to the Civ.R. 56(C) standard. However, the entry contains no analysis

whatsoever as to how it reached its decision to decree Mr. Kneebusch the trustee of the property,

and order title to the property transferred to Mrs. Kneebusch, in light of the parties’ competing

factual and legal theories of the case. This Court, in essence, would have to create an analysis in

order to review it. Indeed, “[w]here a trial court’s judgment is not sufficiently detailed, a

reviewing court may be left in the unfortunate position of being unable to provide meaningful

review.” Zemla v. Zemla, 2012-Ohio-2829, ¶ 19 (9th Dist.). See also Mourton v. Finn, 2012-

Ohio-3341, ¶ 9 (9th Dist.) (“Practically speaking, if a trial court does not set forth any analysis,

the parties may just as well file their summary judgment motions in this Court.”). See Steven A.

Ettinger, Inc. v. Kramer, 2021-Ohio-2219, ¶ 17 (9th Dist.) (“This Court, therefore, reverses and

remands the matter so that the trial court can set forth an analysis that permits our review.”). {¶11} Accordingly, because the trial court’s judgment entry does not provide any analysis

regarding the parties’ respective arguments as set forth in their pleadings and briefs, Mr.

Kneebusch’s first assignment of error is sustained.

ASSIGNMENT OF ERROR II

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Related

Zemla v. Zemla
2012 Ohio 2829 (Ohio Court of Appeals, 2012)
MSRK, L.L.C. v. Twinsburg
2012 Ohio 2608 (Ohio Court of Appeals, 2012)
Pitts v. Sibert
2015 Ohio 3020 (Ohio Court of Appeals, 2015)
Steven A. Ettinger, Inc. v. Kramer
2021 Ohio 2219 (Ohio Court of Appeals, 2021)
Temple v. Wean United, Inc.
364 N.E.2d 267 (Ohio Supreme Court, 1977)

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Bluebook (online)
Kneebusch v. Kneebusch, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kneebusch-v-kneebusch-ohioctapp-2026.