Plum Tree Realty v. Huff-Drees Realty

2024 Ohio 4960
CourtOhio Court of Appeals
DecidedOctober 15, 2024
DocketCA2024-03-008
StatusPublished
Cited by1 cases

This text of 2024 Ohio 4960 (Plum Tree Realty v. Huff-Drees Realty) 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
Plum Tree Realty v. Huff-Drees Realty, 2024 Ohio 4960 (Ohio Ct. App. 2024).

Opinion

[Cite as Plum Tree Realty v. Huff-Drees Realty, 2024-Ohio-4960.]

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO

WARREN COUNTY

PLUM TREE REALTY, et al., :

Appellants, : CASE NO. CA2024-03-008

: OPINION - vs - 10/15/2024 :

HUFF-DREES REALTY, INC., et al., :

Appellees. :

CIVIL APPEAL FROM WARREN COUNTY COURT OF COMMON PLEAS Case No. 23CV95993

Garvey Shearer Nordstrom, PSC, and David A. Shearer, Jr., for appellants.

Arnzen, Storm & Turner, PSC, and Aaron A. VanderLaan, for appellees.

PIPER, J.

{¶ 1} Appellants, Plum Tree Realty, Inc., Scott Ross, and Jason Ross, appeal a

decision of the Warren County Court of Common Pleas. The dispute centers on the

entitlement to a real estate commission that was resolved before an arbitration panel.

Facts and Procedural History

{¶ 2} As an initial matter, we note there is limited information before this court, as

appellants failed to file a transcript of the arbitration proceedings. Nevertheless, the Warren CA2024-03-008

record reflects that appellees, Huff-Drees Realty, Inc., Kelly Kehoe, and Charlie Dean

were the listing agents for a property for sale in Maineville, Ohio ("Property"). Scott Ross

entered into a purchase agreement to purchase the Property with Kelly serving as a dual

agent, representing both Scott Ross and the seller. The purchase agreement was

attached to appellants' complaint.

{¶ 3} Despite the purchase agreement, appellants claim that Jason Ross, Scott's

brother, was entitled to a three percent commission for the sale of the Property. As

relevant here, Jason is a real estate agent with Plum Tree Realty. The record reflects

that in order to move forward with closing Huff Realty agreed to pay Jason of Plum Tree

Realty the three percent commission ("disputed commission") in the amount of $21,000.

The matter proceeded to closing and Plum Tree Realty was provided with the disputed

commission.

{¶ 4} On June 21, 2022, Kelly and Charlie with Huff Realty filed a demand for

arbitration on the issue of the disputed commission. Plum Tree Realty and Jason

responded and agreed to arbitrate the dispute. The matter proceeded to arbitration

before a panel of three arbitrators of the Professional Standards Committee of the Realtor

Alliance of Greater Cincinnati. On March 3, 2023, the arbitrators found that Kelly and

Charlie with Huff Realty were entitled to the disputed commission.

{¶ 5} On April 5, 2023, appellants filed a complaint in the Warren County Court

of Common Pleas against appellees asserting claims for breach of contract, breach of the

covenant of good faith and fair dealing, fraud, fraudulent inducement, and unjust

enrichment. The claims all related to the disputed commission that had been arbitrated.

Appellants later filed a motion to vacate the arbitration award, and appellees filed a

-2- Warren CA2024-03-008

corresponding motion to have the arbitration award confirmed.1

{¶ 6} On August 28, 2023, the common pleas court granted a partial motion to

dismiss on the claims raised by Plum Tree Realty and Jason, as they were parties to the

arbitration proceedings.2 On November 28, 2023, the common pleas court granted the

motion to confirm the arbitration award and denied the motion to vacate the award. The

common pleas court observed that no transcript of the arbitration proceedings had been

filed and the court "must presume the regularity of the arbitration proceedings." Later,

the common pleas court issued a final appealable order awarding appellees attorney fees

in the amount of $11,475 and litigation expenses in the amount of $83.84. Appellants

now appeal, raising three assignments of error for review.

{¶ 7} Assignment of Error No. 1:

{¶ 8} THE TRIAL COURT ERRED TO THE PREJUDICE OF PLAINTIFFS-

APPELLANTS, PLUM TREE REALTY AND JASON ROSS, BY FAILING TO VACATE

THE ARBITRATION AWARD DESPITE RC 2711.10 MANDATORY "SHALL"

LANGUAGE.

{¶ 9} Arbitration is a favored method of dispute resolution. Buchholz v. W.

Chester Dental Group, 2008-Ohio-5299, ¶ 14 (12th Dist.). "The purpose of giving lasting

effect to an arbitration award is to honor the parties' decision to circumvent the traditional

court-based litigation process." Hogan v. Hogan, 2008-Ohio-6571, ¶ 15 (12th Dist.). If

parties cannot rely on the arbitrator's decision, the parties have lost the benefit of their

bargain. Arbitration, which is intended to avoid litigation, would instead become merely

1. The common pleas court stated that appellants pursued this matter irregularly, noting that "the procedural avenue for challenging an arbitration award is by motion and not by complaint." The subsequent filings of the motion to vacate and motion to confirm appear to have resolved some of the earlier confusion encountered by the common pleas court.

2. The common pleas court did not dismiss the claims raised by Scott, as he was not a party to the arbitration proceedings.

-3- Warren CA2024-03-008

a system of "junior varsity trial courts." Rather, "[p]arties who agree to resolve their

disputes via binding arbitration agree to accept the result, even if the arbitrator's decision

is based on factual inaccuracies or the arbitrator's incorrect legal analysis." Id.

Standard of Review

{¶ 10} Because arbitration is encouraged, courts have limited authority to review

an arbitration award. Ohio Patrolmen's Benevolent Assn. v. Trenton, 2013-Ohio-3311, ¶

18 (12th Dist.). In the common pleas court, "the review is limited to determining whether

the party challenging the award has established a ground set forth in R.C. 2711.09

through 2711.14." Buchholz at ¶ 15.

{¶ 11} Pursuant to R.C. 2711.10, a common pleas court can vacate a binding

arbitration award, but only in certain specified situations. These include:

(A) The award was procured by corruption, fraud, or undue means.

(B) There was evident partiality or corruption on the part of the arbitrators, or any of them.

(C) The arbitrators were guilty of misconduct in . . . refusing to hear evidence . . . or of any other misbehavior by which the rights of any party have been prejudiced.

(D) The arbitrators exceeded their powers, or so imperfectly executed them that a mutual, final, and definite award upon the subject matter submitted was not made.

{¶ 12} An appellate court's review of the common pleas court's arbitration order is

confined to the order issued by the common pleas court confirming, modifying, vacating

or enforcing the award. In re Hamilton v. Internatl. Union of Operating Engs., Local 20,

2016-Ohio-5565, ¶ 12 (12th Dist.). An appellate court should "accept findings of fact that

are not clearly erroneous but decide questions of law de novo." Portage Cty. Bd. of Dev.

Disabilities v. Portage Cty. Educators' Assn. for Dev. Disabilities, 2018-Ohio-1590, ¶ 23.

However, this de novo review is narrowly focused. "It does not invite a reexamination of

-4- Warren CA2024-03-008

the merits of the underlying dispute as presented to the arbitrator." Fairfield v. Internatl.

Union of Operating Engs., Local 20, 2024-Ohio-2850, ¶ 14 (12th Dist.). The reviewing

court's task is to determine whether the common pleas court correctly applied the limited

statutory bases for overturning an arbitration award, not to substitute its judgment for that

of the arbitrator on the substantive issues in contention. Id.

Analysis

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Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 4960, Counsel Stack Legal Research, https://law.counselstack.com/opinion/plum-tree-realty-v-huff-drees-realty-ohioctapp-2024.