Ponsart v. Arnold

2024 Ohio 640, 236 N.E.3d 830
Ohio Court of Appeals·Decided February 20, 2024·No. 2023-G-0030·Published

Opinion

[Cite as Ponsart v. Arnold, 2024-Ohio-640.]

IN THE COURT OF APPEALS OF OHIO ELEVENTH APPELLATE DISTRICT GEAUGA COUNTY

MICHAEL PONSART, et al., CASE NO. 2023-G-0030

Plaintiffs-Appellants, Civil Appeal from the - vs - Court of Common Pleas

CHERYL ARNOLD, et al., Trial Court No. 2021 P 000668 Defendants-Appellees.

OPINION

Decided: February 20, 2024 Judgment: Affirmed

Evan T. Byron, Kaufman, Drozdowski & Grendell, LLC, 29525 Chagrin Boulevard, Suite 250, Pepper Pike, OH 44122 (For Plaintiffs-Appellants).

Josephine L. Begin, Manning & Clair, Attorneys at Law, 38040 Euclid Avenue, Willoughby, OH 44094 (For Defendants-Appellees).

JOHN J. EKLUND, J.

{¶1} Appellants, Michael and Sandra Ponsart (the Ponsarts) and Dave and

Sharon Hathy (the Hathys), appeal the judgment of the Geauga County Court of Common

Pleas granting summary judgment in favor of the appellees, Cheryl and Don Arnold and

three companies the two jointly own: Heritage Hills RV Park, LLC, Thompson/Grand River

Valley KOA, LLC, and Heritage Hills Campground, LLC. Appellants claimed that

appellees violated the terms of seasonal contracts for the use of recreational campsites

by disallowing the sale, transfer, or assignment of the rights to the remaining season’s

campsite as a package deal with campsite user’s recreational vehicles currently on site. Appellants alleged breach of contract and tortious interference with a business

relationship.

{¶2} Appellants raise two assignments of error, arguing the trial court erred by

granting summary judgment on their breach of contract claim and tortious interference

with a business relationship claim.

{¶3} Having reviewed the record and the applicable caselaw, we find appellants’

assignments of error are without merit. First, the campsite transfer policy was a

nonassignable and unwritten revocable policy. Appellees did not commit a breach by

changing the policy midseason. Second, appellees did not tortiously interfere with a

business relationship because appellants failed to establish that any business relationship

existed. Further, as owners of the campsite, appellees were privileged to limit the transfer,

sale, or assignment of the rights to a campsite.

{¶4} Therefore, we affirm the judgment of the Geauga County Court of Common

Pleas.

Substantive and Procedural History

{¶5} Appellees owned a recreational campground in Geauga County. The

campsite had three types of campers: overnight, monthly, and seasonal. Seasonal camp

users paid for the entire camp season: May 1 through October 31. Seasonal camp users

signed a campsite use agreement. The agreement provided:

This agreement is not a lease. It is a contract which is binding on both the campground and the camper. This agreement is not a lease of real estate. The camper is not a tenant. This agreement is, for legal purposes, a license to use the property of the campground on the conditions which are stated in this agreement.

Case No. 2023-G-0030 Seasonal camp users were given the opportunity to make a deposit and reserve the next

year’s site. Any lot not secured by a deposit could be opened to individuals on a waiting

list. Cheryl Arnold testified that the waiting list had approximately 500 people on it. The

Ponsarts and Hathys both became seasonal camp users in 2016. The Hathys began

camping by purchasing an existing recreational vehicle (RV) on site.

{¶6} In 2016, the campsite use agreement provided that RVs more than ten

years old would not be accepted unless they were already located on a campsite. The

campsite use agreement also provided that “If your Motorhome or Travel Trailer is

older than the requirement, it cannot be sold and left here at the park. Please

discuss any pending sale with Don if the plans are to leave it at the park. We will

need to meet the new owners and determine if they fit the neighborhood/park. We

have a great group of people and want to keep it that way.” (Bold in original.)

{¶7} However, this language was removed from the campsite use agreement for

the 2017 season onward. Additionally, in August 2018, appellees sent a letter to notify

camp users that certain camp sites would no longer be used as seasonal sites. The notice

stated:

If you are planning to sell your camper in the future * * *. In the above sections, you will not be able to sell your lot and camper as a package deal. When you leave, your lot will no longer be a seasonal lot. Very important to keep in mind and if you have questions, please come ask. This DOES NOT affect current seasonals staying on these lots, just the selling of your lot and camper when you no longer want to be here.

After receiving this letter, the Hathys chose to move their campsite from one of the

affected sites. Cheryl testified the reason for this change was to afford easier in and out

access to day camp users and because seasonal camping is less profitable.

Case No. 2023-G-0030 {¶8} For the 2020 season, the pertinent year for this lawsuit, the RV age

limitation provision made no reference to leaving the RV at the site as a condition of the

sale. In September 2020, appellees sent a notice to formally end the policy of allowing

people to assume a seasonal site and priority for reserving their site in the following year

when a campsite user sold their RV. That notice read:

Addendum to contract: Due to the high demand and extremely long wait list, we have decided to no longer allow the selling of your camper with the lot. We feel as though this is unfair to the people who we are placing on the list, who already have campers, and want a seasonal spot. If we have the information regarding selling your camper prior to the packets being sent out on 9/20/2020, you will be allowed to continue with the sale.

{¶9} Neither the Ponsarts nor the Hathys had placed their RVs on sale by this

point. However, appellants maintain that due to the long waitlist, “had they listed their

campers/sites for sale * * * it is a virtual certainty that * * * both would have had multiple

offers.” (Brief in Opp. to MSJ, pp. 17-18.).

{¶10} On November 5, 2021, appellants filed a complaint with counts for breach

of contract, tortious interference with a business relationship, fraud, deceptive trade

practices, and unjust enrichment.

{¶11} On May 2, 2023, appellees filed a motion for summary judgment. Appellants

responded in opposition, and appellees filed a reply. At this time, appellants dismissed

their fraud and deceptive trade practices claims.

{¶12} On July 27, 2023, the trial court issued an order granting appellees’ motion

for summary judgment. The trial court’s order noted that the salient facts were not in

dispute and concluded appellees ended their “unwritten policy allowing some seasonal

sites to be sold by the respective licensees to applicants.” The court determined

appellants had not identified any “real or prospective buyers prior to the expiration of their 4

Case No. 2023-G-0030 2020 Contracts” but claimed they would have sold ahead of time had they known about

the policy change.

{¶13} The trial court concluded the campsite use agreement was a license to use

the property and as such did not provide appellants “a right to sell or transfer their license

to use any campsite. [Appellants] do not identify any language in the Contract to prove

otherwise.” The trial court noted that under R.C. 1335.05, the statute of frauds requires

promises creating an interest in land to be in writing.

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Ponsart v. Arnold, 2024 Ohio 640, 236 N.E.3d 830 (Ohio Ct. App. 2024).

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