Mitiwanga Park Co. v. Sablack

2015 Ohio 3945
CourtOhio Court of Appeals
DecidedSeptember 25, 2015
DocketE-15-001, E-15-002, E-15-003, E-15-004, E-15-005
StatusPublished

This text of 2015 Ohio 3945 (Mitiwanga Park Co. v. Sablack) 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
Mitiwanga Park Co. v. Sablack, 2015 Ohio 3945 (Ohio Ct. App. 2015).

Opinion

[Cite as Mitiwanga Park Co. v. Sablack, 2015-Ohio-3945.]

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

The Mitiwanga Park Company Court of Appeals Nos. E-15-001 E-15-002 Appellant E-15-003 E-15-004 v. E-15-005

Dezso Sablack, et al. Trial Court Nos. CVF 1300353 CVF 1300354 Appellees CVF 1300355 CVF 1300356 CVF 1300357

DECISION AND JUDGMENT

Decided: September 25, 2015

*****

Joseph E. DiBaggio and Robert E. Kmiecik, for appellant.

Raymond V. Vasvari, Jr., for appellee Dezso Sablack.

George C. Wilber, for appellees Connie Holland and Sandy Beach Apartments, Ltd.

PIETRYKOWSKI, J.

{¶ 1} Appellant, Mitiwanga Park Company appeals the November 25, 2014

judgment of the Vermilion Municipal Court which granted summary judgment in favor of property owners Dezso Sablack, Connie Holland, and Sandy Beach Apartments, Ltd. on

its claims for funds it alleged were due for reasonable use and maintenance of common

areas of the development. Because we agree that no genuine issue of fact remains, we

affirm.

{¶ 2} Mitiwanga Subdivision is located in Erie County, Ohio, on the shores of

Lake Erie. It was incorporated in 1915. Mitiwanga Park Company (“Mitiwanga”) is a

property owner’s association and its bylaws were incorporated on October 7, 1987.

Mitiwanga claims title to the common areas, i.e. property not owned by individual

owners, in the subdivision including the roads, park area, lakefront and beach.

{¶ 3} In a prior action before this court, Mitiwanga claimed the right to enforce the

bylaws as to all lot owners based upon the contractual restrictions that it claimed the

property owners had constructive knowledge of when they purchased their property

(excluding those whose lot ownership predated the 1987 incorporation date.) Sandy

Beach Apt. Ltd. v. Mitiwanga Park Co., 6th Dist. Erie Nos. E-06-041, E-06-040, E-06-

042, 2008-Ohio-606. Reviewing the trial court’s award of summary judgment to

Mitiwanga, we found that the bylaws, by way of their inception, could not be considered

restrictive covenants that ran with the land. Id. at ¶ 36. We further held that Mitiwanga

was not entitled to reimbursement of the maintenance costs under a theory of unjust

enrichment. Specifically, we noted that “Mitiwanga proceeded, without an agreement, to

maintain the common areas and then attempted to force appellants to pay what

Mitiwanga determined to be their share of the cost * * * [a] finding of unjust enrichment

2. under such circumstances would not be equitable and is contrary to law.” Id. at ¶ 43.

This court then reversed the summary judgment award and remanded the matter to the

trial court to declare the rights of the parties under the deeds. Id. at ¶ 46.

{¶ 4} On remand, appellee Sablack and Mitiwanga entered a joint stipulation of

dismissal, with prejudice. As to appellees Holland and Sandy Beach, on June 28, 2010,

the trial court found that appellees, pursuant to an implied easement, had unrestricted use

of the streets, avenues, and parks. The court further noted that Holland and Sandy Beach,

as the owners of the dominant estate, had the responsibility to make the necessary repairs;

because Mitiwanga voluntarily made the repairs, it was not entitled to restitution under an

unjust enrichment theory. The court then concluded:

[E]ven though the common law principle establishes the fact that

Plaintiff is responsible for making repairs, Ohio case law recognizes that

courts have properly determined the relative use of each party and

apportioned the expenses incurred in maintaining and repairing the

easement accordingly. There is nothing before this Court which denotes

that a repair to any easement is necessary at this time. Moreover, it is true

that Plaintiffs are not required to maintain the easement area to a level to be

determined by the Defendant. However, since both parties jointly use the

easements it would be only fair that Plaintiffs contribute their proportionate

share, if repairs are necessary, to prevent the enjoyment of the easement

from becoming an annoyance. With that stated, however, this does not

3. mean that the Defendant has the responsibility to determine when and how

such expense should be established. Thus the Court determines that if and

when repairs are necessary, Plaintiffs and the Defendant shall determine the

relative use of each party and proportion the cost accordingly. Sandy

Beach Apt. Ltd. v. Mitiwanga Park Co., Erie C.P. No. 2000-CV-454

(June 28, 2010.)

No appeal was taken from the judgment.

{¶ 5} On November 13, 2013, Mitiwanga commenced five small claims actions in

the Vermilion Municipal Court. Two actions named appellee Sablack and involved two

parcels of property and a claim to recover funds for the use and benefit of roadways and

services maintained by Mitiwanga during 2011. Three similar claims were filed against

appellee Holland and Sandy Beach Apartments (with Holland as the sole member of the

limited liability company.)

{¶ 6} By motions of appellees, the court transferred the cases to the regular docket

of the Vermilion Municipal Court. On July 17, 2014, Sablack filed his motion for

summary judgment. Sablack argued that appellant was estopped from asserting its claims

based on this court’s 2008 decision. Specifically, Sablack argued that Mitiwanga’s

monetary claims for “reasonable use” of the roadways and common areas for 2011 was

barred by res judicata. Sablack further contended that Mitiwanga’s claims were preluded

whether or not they were based upon the same legal theories. Sablack asserted that he

was not legally required to pay the charges asserted in the case.

4. {¶ 7} On the same date, Holland and Sandy Beach filed motions for summary

judgment also arguing that the claims were barred by res judicata. The parties explained

that the cases involved the same parties and involved “a common nucleus of operative

facts,” thereby precluding relitigation.

{¶ 8} In opposition, Mitiwanga argued that its claims were not based in contract or

under the theory of unjust enrichment which had previously been rejected by this court;

rather, it was seeking to enforce its rights under an implied easement. Mitiwanga claimed

that based upon the easement, appellees, by law, were required to pay their proportionate

share of the expenses. Relying on the language in the trial court’s 2010 decision,

Mitiwanga stated that appellees, as owners of the dominant estate, were required to make

certain repairs. Because they failed to do so Mitiwanga, as the owner of the servient

estate, was obligated to perform them and was entitled to reimbursement for the repairs it

undertook.

{¶ 9} In response, the parties argued that no new legal theory was raised in

Mitiwanga’s case and that even considering it as a new claim because it could have been

raised in the previous action, Mitiwanga was estopped from raising it. Further as to

Sablack, he argued that he and Mitiwanga settled their dispute; thus, Sablack was not

bound to the lower court’s 2010 decision following remand. Appellees further argued

that unlike the dictates of the trial court’s prior decision, there had been no agreement

between the parties as to what repairs were necessary and how payment would be

5. apportioned. Appellees asserted that Mitiwanga was not authorized to “unilaterally”

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