Link v. Kelly

2025 Ohio 711
CourtOhio Court of Appeals
DecidedMarch 3, 2025
Docket8-24-16
StatusPublished

This text of 2025 Ohio 711 (Link v. Kelly) 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
Link v. Kelly, 2025 Ohio 711 (Ohio Ct. App. 2025).

Opinion

[Cite as Link v. Kelly, 2025-Ohio-711.]

IN THE COURT OF APPEALS OF OHIO THIRD APPELLATE DISTRICT LOGAN COUNTY

DAVE LINK, CASE NO. 8-24-16 PLAINTIFF-APPELLANT,

v.

CLIFFORD E. KELLY, OPINION

DEFENDANT-APPELLEE.

Appeal from Logan County Common Pleas Court General Division Trial Court No. CV 21 11 0248

Judgment Reversed and Cause Remanded

Date of Decision: March 3, 2025

APPEARANCES:

Stanley R. Evans for Appellant

Terrence G. Stolly for Appellee Case No. 8-24-16

WALDICK, P.J.

{¶1} Plaintiff-appellant, Dave Link (“Link”), appeals the judgment granted

in favor of defendant-appellee, Clifford Kelly (“Kelly”), in the Logan County Court

of Common Pleas, following a trial to the court on Link’s complaint seeking specific

performance and monetary damages related to a contract for the purchase of real

property owned by Kelly.

Procedural History

{¶2} This case originated on November 22, 2021, when Link filed a

complaint against Kelly in the trial court, alleging that on September 3, 2021, Link

and Kelly had entered into a binding written contract pursuant to which Kelly was

obligated to sell approximately 120 acres of farm land to Link for $988,650.00. The

complaint alleged that the parties had agreed to a closing date of no later than

October 8, 2021, but that Kelly had refused to close the transaction as required by

the contract. The complaint alleged that Link was ready, willing, and able to

perform his remaining obligations under the contract and that he had performed all

other conditions precedent required of him by the contract, but that Kelly refused to

accept Link’s tender of the purchase price and convey the real property to Link. The

complaint sought specific performance of the contract, specifically an order

requiring Kelly to sell and convey the real estate at issue. The complaint also sought

monetary damages for financial loss alleged to have been incurred by Link as a

result of Kelly’s alleged breach of contract.

-2- Case No. 8-24-16

{¶3} On January 12, 2022, Kelly filed an answer to the complaint, in which

the bulk of the allegations in the complaint were denied or not addressed, although

Kelly admitted that he would not close the transaction.

{¶4} On February 28, 2022, Link filed a motion to enforce settlement, which

Kelly opposed on March 8, 2022. On May 3, 2022, the trial court held an

evidentiary hearing on Link’s motion. On May 11, 2022, the trial court filed a

judgment entry denying the motion to enforce settlement.

{¶5} On September 2, 2022, Kelly filed a motion for leave to file a third-

party complaint against Oakridge Realty and Auction Company and Kevin Miller,

which the trial court granted by judgment entry filed on November 22, 2022. On

December 1, 2022, Kelly filed a third-party complaint against Oakridge and

Miller. On December 12, 2022, Oakridge and Miller filed their answer and a

counterclaim against Kelly.

{¶6} On September 18, 2023, Link filed a motion for partial summary

judgment, requesting that summary judgment be granted in his favor on the claim

for specific performance. On October 16, 2023, Kelly filed a memorandum in

opposition to Link’s motion for summary judgment. On November 16, 2023, the

trial court filed a judgment entry overruling Link’s motion for summary judgment.

{¶7} On December 13, 2023, a trial to the court was held. On that same date,

Link and Kelly filed a set of joint stipulations of fact with the trial court.

-3- Case No. 8-24-16

{¶8} On February 5, 2024, the trial court filed a judgment entry in which the

court made findings of facts and conclusions of law, and entered judgment in favor

of Kelly.

{¶9} On February 29, 2024, Kelly and the third-party defendants filed a joint

stipulation of dismissal of their respective claims against each other.

{¶10} On March 1, 2024, the trial court filed an entry of final judgment.

{¶11} On March 28, 2024, Kelly filed the instant appeal, in which he raises

nine assignments of error for our review.

First Assignment of Error

The trial court erred in denying appellant’s motion to enforce settlement agreement.

Second Assignment of Error

The trial court erred in denying appellant’s motion for summary judgment.

Third Assignment of Error

The trial court abused its discretion by considering materials not introduced at trial.

Fourth Assignment of Error

The trial court erred by concluding that appellant implicitly consented to try the defense of impossibility.

Fifth Assignment of Error

The trial court abused its discretion in raising and considering the improperly pled defense of mutual mistake.

-4- Case No. 8-24-16

Sixth Assignment of Error

The trial court abused its discretion in raising for and on behalf of appellee the unpled affirmative defenses of denial of the performance and occurrence of conditions precedent.

Seventh Assignment of Error

The trial court erred as a matter of law in concluding that the sale of the 120.567 acres resulting in the creation of the landlocked parcels constitutes mutual mistake.

Eighth Assignment of Error

The trial court erred as a matter of law by not allocating the risk of mutual mistake against appellee.

Ninth Assignment of Error

The trial court erred in concluding that specific performance would be excessively oppressive.

{¶12} In the first assignment of error, Link asserts that the trial court erred in

overruling his motion to enforce a settlement agreement.

{¶13} As previously noted, Link filed the complaint against Kelly on

November 22, 2021. Approximately three months later, on February 28, 2022, Link

filed a motion to enforce settlement. In that motion, Link contended that, through

his attorney, he had entered into a binding settlement agreement with Kelly, through

Kelly’s attorney, and that Kelly was attempting to rescind that settlement agreement

that would have resolved the lawsuit. On March 8, 2022, Kelly filed a memorandum

in opposition to the motion to enforce settlement, arguing that no binding settlement

-5- Case No. 8-24-16

agreement existed because there had been no definite offer regarding settlement and

no acceptance thereof. Kelly also asserted that he never gave authorization to his

prior counsel to enter into any settlement agreement.

{¶14} On May 3, 2022, the trial court held an evidentiary hearing on Link’s

motion to enforce settlement. On May 11, 2022, the trial court filed a judgment

entry denying Link’s motion, finding for several reasons that the parties had not

entered into an enforceable settlement agreement.

{¶15} A settlement agreement is a contract designed to terminate a claim by

preventing or ending litigation. Continental W. Condominium Unit Owners Assn. v.

Howard E. Ferguson, Inc., 74 Ohio St.3d 501, 502 (1996). As with any other

contract, a settlement agreement requires an offer, acceptance, consideration, and

mutual assent between two or more parties with the legal capacity to act. See,

e.g., Kostelnik v. Helper, 2002-Ohio-2985, ¶ 16; Rulli v. Fan Co., 79 Ohio St.3d

374, 376 (1997).

{¶16} For a settlement agreement to be enforceable, there must be a “meeting

of the minds” as to the essential terms of the agreement. Kostelnik, at ¶ 16. The

essential terms of the agreement must be “reasonably certain and clear.” Kostelnik,

at ¶ 17.

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2025 Ohio 711, Counsel Stack Legal Research, https://law.counselstack.com/opinion/link-v-kelly-ohioctapp-2025.