Marchbanks v. JPMorgan Chase Bank, N.A.

2024 Ohio 5876
CourtOhio Court of Appeals
DecidedDecember 16, 2024
Docket2024-T-0041
StatusPublished

This text of 2024 Ohio 5876 (Marchbanks v. JPMorgan Chase Bank, N.A.) 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
Marchbanks v. JPMorgan Chase Bank, N.A., 2024 Ohio 5876 (Ohio Ct. App. 2024).

Opinion

[Cite as Marchbanks v. JPMorgan Chase Bank, N.A., 2024-Ohio-5876.]

IN THE COURT OF APPEALS OF OHIO ELEVENTH APPELLATE DISTRICT TRUMBULL

JACK MARCHBANKS, DIRECTOR, CASE NO. 2024-T-0041 OHIO DEPARTMENT OF TRANSPORTATION, Civil Appeal from the Plaintiff-Appellee, Court of Common Pleas

- vs - Trial Court No. 2022 CV 01605 JPMORGAN CHASE BANK, N.A., SUCCESSOR BY MERGER TO BANK ONE, YOUNGSTOWN, N.A., AN OHIO CORPORATION, et al.,

Defendant-Appellant.

OPINION

Decided: December 16, 2024 Judgment: Affirmed

Dave Yost, Ohio Attorney General, State Office Tower, 30 East Broad Street, 16th Floor, Columbus, OH 43215, and Shantae DeCarlo and William J. Cole, Senior Assistant Attorney Generals, Executive Agencies Section, Transportation Unit, 30 East Broad Street, 26th Floor, Columbus, OH 43215 (For Plaintiff-Appellee).

William M. Mattes, Charles E. Ticknor, III, and Gregory P. Mathews, Dinsmore & Shohl LLP, 191 West Nationwide Boulevard, Suite 200, Columbus, OH 43215 (For Defendant- Appellant).

ROBERT J. PATTON, J.

{¶1} Appellant, JPMorgan Chase Bank, N.A. (“Chase”), appeals the decision of

the Trumbull County Court of Common Pleas granting summary judgment in favor of

appellee, Jack Marchbanks, Director, Ohio Department of Transportation (“ODOT”). For

the following reasons, we affirm. {¶2} This appeal arises from the appropriation of two parcels of land owned by

Chase. On November 17, 2022, ODOT initiated an appropriation action in the Trumbull

County Court of Common Pleas. In its petition, ODOT sought to acquire a temporary

easement over one of the parcels owned by Chase, and to acquire fee simple in the other.

In ODOT’s petition it identified the parcel it sought a temporary easement over as “Parcel

21-T,” and the parcel it sought fee simple in as “Parcel 21-WD.”1 This appeal only

concerns the parcel of land to which ODOT sought fee simple.

{¶3} The stated purpose for the appropriation was for “making, constructing,

repairing or improving a state, U.S. or Interstate highway which shall be open to the public,

without charge.” Appellee’s Petition, Dkt. 1, p. 2. On April 15, 2024, the trial court issued

a judgment entry granting summary judgment in favor of ODOT, approving the temporary

easement over the first parcel, and ordering Chase to execute a warranty deed for the

second parcel to ODOT.

{¶4} The parties do not dispute that ODOT’s appropriation was lawful, nor do

they dispute the value to be conferred to Chase for the appropriation. Instead, Chase

challenges the decision of the trial court ordering Chase to execute to ODOT a warranty

deed. Chase’s principal argument is that implicit in a warranty deed is the covenant of

warranty, which includes a promise made by the grantor to defend the grantee from future

claims against title. Chase contends that the trial court exceeded the scope of its authority

by not only approving ODOT’s appropriation of property, but by ordering Chase to execute

1. Attached to its petition, ODOT included a separate legal description for each parcel it sought to acquire. However, the Trumbull County Auditor Parcel Number, that was included with the legal descriptions provided, are identical (Parcl No. 28-293125). 2

Case No. 2024-T-0041 a warranty deed that would essentially include the promise to indemnify a government

agency against future claims against good title.

Assignments of Error

{¶5} In this appeal, Chase asserts two assignments of error:

{¶6} [1.] “The trial court erred in granting ODOT’s motion for summary judgment

because Ohio law does not authorize a state agency to appropriate a warranty deed.”

{¶7} [2.] “The trial court erred in granting ODOT’s motion for summary judgment

because the motion did not comply with Civ.R. 56.”

{¶8} At issue is whether it was proper for the trial court to grant summary

judgment in favor of ODOT, whether the trial court had authority to order Chase to execute

a Warranty Deed to ODOT for the appropriated property, and if ODOT’s motion for

summary judgment complied with Ohio Civ.R. 56(C).

Standard of Review

{¶9} We review a trial court’s decision to grant summary judgment under a de

novo standard of review.

{¶10} “A trial court’s decision to grant summary judgment is reviewed by an

appellate court under a de novo standard of review.” McFadden v. Discerni, 2023-Ohio-

1086, ¶ 12 (11th Dist.) (citing Grafton v. Ohio Edison Co., 77 Ohio St.3d 102, 105). “‘A de

novo review requires the appellate court to conduct an independent review of the

evidence before the trial court without deference to the trial court’s decision.’” Id. quoting

Peer v. Sayers, 2011-Ohio-5439, ¶ 27 (11th Dist.).

{¶11} Summary judgment is proper when it appears from the evidence that

reasonable minds can come to but one conclusion:

Case No. 2024-T-0041 [S]ummary judgment is proper “when (1) the evidence shows ‘that there is no genuine issue as to any material fact’ to be litigated, (2) ‘the moving party is entitled to judgment as a matter of law,’ and (3) ‘it appears from the evidence * * * that reasonable minds can come only to but one conclusion and that conclusion is adverse to the party against whom the motion for summary judgment is made, that party being entitled to have the evidence * * * construed most strongly in the party’s favor.’ ”

Id. at ¶ 11, quoting Civ.R. 56(C).

First Assignment of Error

{¶12} Chase directs the Court to three issues for review.

{¶13} First, Chase asserts that R.C. Chapter 163 does not authorize a state

agency to “appropriate a deed.”

{¶14} Second, Chase contends that R.C. Chapter 163 does not authorize a state

agency or court to compel a property owner to make covenants of title concerning the

appropriated property.

{¶15} Third, Chase further asserts that a property owner contesting a state

agency’s authority to take a warranty deed, but not the agency’s right or necessity to

appropriate the property, is not required to seek an injunction to prevent the appropriation.

Eminent Domain

{¶16} “The Ohio Constitution states that ‘private property shall ever be held

inviolate, but subservient to the public welfare. * * * Where private property shall be taken

for public use, a compensation shall be assessed * * *.’ ” Bacak v. Trumbull Cty. Bd. of

Commrs., 2016-Ohio-4737, ¶ 57 (11th Dist.), quoting State ex. rel. OTR v. City of

Columbus, 76 Ohio St.3d 203, 206. “A taking occurs when a landowner experiences a

substantial or unreasonable interference with property. * * * That interference may involve

Case No. 2024-T-0041 an actual physical taking of real property or it may include the deprivation of an intangible

interest in the premises.” Id.

{¶17} “Though the Ohio Constitution may bestow on the sovereign a magnificent

power to take private property against the will of the individual who owns it, it also confers

an ‘inviolable’ right of property on the people. When the [S]tate elects to take private

property without the owner’s consent, simple justice requires that the [S]tate proceed with

due concern for the venerable rights it is preempting.” Norwood v. Horney, 2006-Ohio-

3799, at ¶ 68 citing Cleveland v. Hurwitz, 19 Ohio Misc. 184, 192 (C.P. 1969).

{¶18} An appropriation action is the procedural device provided by statute to carry

out the state government’s eminent domain power, otherwise known as a condemnation

proceeding. Section 163.63 of the Ohio Revised Code provides clarification:

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2024 Ohio 5876, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marchbanks-v-jpmorgan-chase-bank-na-ohioctapp-2024.