Rolph v. Rolph

Ohio Court of Appeals·Decided August 4, 2026·No. CA2025-08-013·Published

Opinion

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO BROWN COUNTY

MARTIN ROLPH, et al., :

CASE NO. CA2025-08-013

Appellees, :

OPINION AND

vs. : JUDGMENT ENTRY 8/4/2026

DANIEL ROLPH, et al., :

Appellants. :

:

CIVIL APPEAL FROM BROWN COUNTY COURT OF COMMON PLEAS Case No. 2023-0418

Cors & Bassett, LLC, and Kevin R. Feazell; and Patrick J. Gregory and David E. Grimes, for appellees.

Yonas & Phillabaum, LLC, and Jason Phillabaum, James Boyd, and Hope Platzbecker, for appellants.

OPINION

BYRNE, P.J.

{¶ 1} Plaintiffs-Appellants, Martin Rolph, James Rolph, Julie Robke, and Luke Rolph (collectively, "Plaintiffs"), appeal from the decision of the Brown County Court of Common Pleas, General Division, which granted summary judgment on all claims in

favor of Defendants-Appellees, Daniel and Christina Rolph (collectively, "Defendants"). For the reasons described below, we affirm.

I. Factual and Procedural Background A. Background Facts

{¶ 2} This matter involves the Estate of Judy Martin Gray and an inter vivos transfer of her real property. The following facts, unless noted, are not in dispute.

{¶ 3} Gray passed away on April 22, 2022. Four of Gray's five children survived her: Plaintiffs Martin, James, and Julie, and Defendant Daniel. Gray's son, Christopher, predeceased her. Christopher had two children, Plaintiff Luke and non-party Grant.

{¶ 4} Gray executed her last will and testament in August 2021. In the will, Gray divided her beneficial estate into five equal shares. Her four surviving children would each receive a one-fifth share. The remaining one-fifth share would be split between Christopher's sons, Plaintiff Luke and non-party Grant.

{¶ 5} At the heart of this dispute is the family farm ("the Farm"), which was an approximate 300-acre farm located at 7618 State Route 505, Felicity, Brown County, Ohio. Gray and her late husband raised their children on the Farm.

{¶ 6} Beginning in or around 2005, Defendant Daniel moved back to the Farm and began working there as a self-employed farmer. He lived in a home on the property next door to Gray. The record is not clear, but it appears that Defendants Daniel and Christina lived together as husband and wife while living at the Farm.

{¶ 7} In 2014, eight years prior to her death, Gray entered into a land contract ("Land Contract") with Defendants Daniel and Christina, allowing them to purchase the Farm. The Land Contract specified a purchase price of $600,000, payable by 10 annual payments of approximately $27,000 per year, with interest accruing at 2% per annum.

Defendants further agreed to pay the outstanding balance in the 11th year, and agreed to obtain financing or other sources of funds to make this final payment.

{¶ 8} At the time Gray entered into the Land Contract, she allegedly wrote a letter to her other children informing them that she had decided to sell the Farm to the Defendants, which would allow them to continue farming and keep the Farm in the family for at least another generation.1 She also stated that the money from this sale would "go into my trust" and what was left would be divided "between the five of you." There is no evidence that Gray created a trust for the benefit of her children or deposited money received from the Land Contract into a trust.

{¶ 9} Beginning in 2015, Defendants began making the annual payments on the Land Contract and paid $27,000 each year until 2020, making a total of six payments totaling $162,000 in principal and interest.

{¶ 10} In August 2020, Gray transferred the Farm by general warranty deed to the Defendants. The deed reflected that it released the Land Contract, and referenced the Land Contract by recorded book and page number. On the same day, Gray transferred her own house by general warranty deed to Plaintiff Julie. At her deposition, Plaintiff Julie testified that she drove Gray to the law office of Gray's attorney, Michael Pfeffer, where the deeds for these two transfers were prepared and executed.

{¶ 11} Gray's last will and testament nominated Michael Pfeffer as Executor of her estate. The will further identified Defendants as alternate co-executors. After Gray's passing, Pfeffer was unable to serve as executor. Defendants thereafter opened Gray's Estate in the Brown County Court of Common Pleas, Probate Division.

1. The letter is in evidence, but some Plaintiffs dispute whether Gray wrote the letter.

B. The Probate Division Matter

{¶ 12} After the Estate was opened and the inventory filed, Plaintiff Martin filed a motion with the probate court to disqualify the Defendants as co-executors, pursuant to R.C. 2113.18. That statute allows a probate court to remove an executor if there are "unsettled claims" between the executor and the estate that the court believes may be the subject of controversy or litigation. Plaintiff Martin alleged that there was approximately $600,000 missing from the estate inventory because Defendants had failed to pay the Land Contract in full. Martin asked the probate court to appoint him estate administrator.

{¶ 13} A magistrate with the probate court held an evidentiary hearing on the motion to disqualify and testimony and evidence was offered. At the conclusion of the hearing, the magistrate orally announced that the transfer of the Farm to the Defendants by deed was a valid transfer. In a subsequent written decision, the magistrate found that the terms of the Land Contract merged with the deed executed in August 2020. The magistrate noted that no exceptions were filed to the inventory, which did not list the Farm as an estate asset. The magistrate overruled the motion to remove the co-executors.

{¶ 14} Plaintiff Martin objected to the magistrate's decision. Martin objected on the basis that (1) removal of the co-executors was required due to the high likelihood of litigation between heirs and co-executors, (2) the magistrate erred by refusing to permit evidence regarding the transfer of the Farm, and (3) the magistrate erred by not taking into account that the vested beneficiaries of Gray's will (other than Defendant Daniel) supported removing Defendants.

{¶ 15} The probate court judge overruled the objections. Like the magistrate, the judge found that the payment terms of the Land Contract merged with the August 2020 transfer by deed. The judge also found no basis to remove the co-executors based on a

"high" probability of litigation. The judge noted that the Land Contract was not listed on the estate inventory and no party had filed exceptions to the inventory. The court found that "unknown litigation" did not require removing the Defendants as co-executors.

{¶ 16} Lastly, the judge found that the magistrate did not err in refusing to permit evidence related to Gray's mental condition at the time of the execution of the August 2020 deeds. The judge found that no medical testimony had been submitted and Plaintiff Julie, who was present for the execution of the deed, "allowed it to happen" and benefitted from the transfer of Gray's home that day. The court questioned why Plaintiff Julie would now question the legitimacy of a transfer in which she was an active participant.

{¶ 17} Plaintiff Martin did not appeal the probate court's decision.

C. The General Division Matter 1. Plaintiffs' Complaint, Defendants' Answer, and Discovery

{¶ 18} Approximately six months later, in July 2023, Plaintiffs filed a complaint in the Brown County Court of Common Pleas, General Division, against Defendants Daniel and Christina, both in their individual capacities and as co-executors of Gray's Estate. In the complaint, Plaintiffs asserted five counts: (1) intentional interference with the expectancy of an inheritance ("IIEI"), (2) fraud, (3) undue influence, (4) unjust enrichment, and (5) quiet title. Only three of those claims have been raised as issues in this appeal: IIEI, fraud, and undue influence.

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