Vogel v. Campanaro

2021 Ohio 4245, 180 N.E.3d 594
CourtOhio Court of Appeals
DecidedDecember 6, 2021
DocketCA2020-07-036
StatusPublished
Cited by4 cases

This text of 2021 Ohio 4245 (Vogel v. Campanaro) 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
Vogel v. Campanaro, 2021 Ohio 4245, 180 N.E.3d 594 (Ohio Ct. App. 2021).

Opinion

[Cite as Vogel v. Campanaro, 2021-Ohio-4245.]

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO

WARREN COUNTY

DAVID VOGEL, :

Appellant, : CASE NO. CA2020-07-036

: OPINION - vs - 12/6/2021 :

BEVERLY CAMPANARO, :

Appellee. :

CIVIL APPEAL FROM WARREN COUNTY COURT OF COMMON PLEAS Case No. 18CV91138

Ronald J. Kozar, for appellant.

Jeffrey E. Richards, for appellee.

HENDRICKSON, J.

{¶1} Appellant, David Vogel, both individually and as cotrustee of the Mardella C.

Vogel Revocable Living Trust Dated July 1, 1994 (hereafter, "Brother"), appeals from the

judgment entered in favor of appellee, Beverly Campanaro, both individually and as co-

trustee of the Mardella C. Vogel Revocable Living Trust Dated July 1, 1994 (hereafter,

"Sister"), following a bench trial on Brother's claims for breach of fiduciary duty, unjust

enrichment, tortious interference with an inheritance, a request for an accounting, and Warren CA2020-07-036

declaratory relief. Brother challenges the trial court's findings that Sister did not use assets

belonging to the parties' mother for Sister's own personal benefit and that Sister did not

engage in self-serving transactions while in a fiduciary position. For the reasons set forth

below, the judgment of the trial court is affirmed in part, reversed in part on jurisdictional

grounds, and remanded.

I. FACTUAL BACKGROUND

{¶2} Brother and Sister are the only children of their parents, Adam P. Vogel

("Father") and Mardella C. Vogel ("Mother"). In 1994, while Father and Mother were in their

70s, they each established individual revocable living trusts.1 Mother's trust was titled the

"Mardella C. Vogel Revocable Living Trust" (hereafter, "Mother's Trust"). The trust

designated Mother as the initial trustee and primary beneficiary for her trust. Mother's Trust

provided that the trustee could authorize signatories to make authorized expenditures from

the trust's various financial accounts. The trust also provided that Mother, as settlor, could

deplete the trust res during her lifetime or even revoke the trust. In the event that Mother

died or ceased to serve as trustee, Father was designated as the alternate trustee. If Father

predeceased Mother, then Brother and Sister were designated as cotrustees. Mother's

Trust was originally funded with one dollar, but additional funds were later deposited into

the checking account.2

{¶3} As Father and Mother aged, they required help with their day-to-day needs.

This included assistance with transportation to doctor appointments and trips to various

retail stores. As Sister was not employed outside the home, she assisted her parents

1. The use of Father's trust is not challenged in this appeal.

2. Furniture, furnishings, jewelry, household goods, and all other personal effects were later added to Mother's trust estate by an amendment. While other funds were added to Mother's trust, the record is silent as to the source of the funds and the amounts and dates the funds were deposited. The record does indicate, however, that when Mother's and Father's marital home – which had been transferred to Brother and Sister – was sold, Sister deposited her half of the sale proceeds, nearly $90,000, into Mother's trust checking account.

-2- Warren CA2020-07-036

almost on a daily basis. In 2013, Father gave Sister possession of his 2009 Lexus RX

vehicle ("Lexus") to use when transporting Mother or Father to their various appointments

or when running errands with them. The title of the Lexus, however, remained in Father's

name and he continued to pay for the vehicle's gas, insurance, and repairs.

{¶4} Mother paid all of her bills out of her trust checking account. In 2013, Sister

began to help Mother manage her finances by writing checks for Mother using the same

trust checking account to pay Mother's bills. According to Sister, Mother never lost her

ability to handle her financial affairs; rather, Mother just lost the desire to do so after paying

one of her bills twice. By the middle of 2015, Sister handled all financial matters for Mother.

Sister testified that Mother's banks were made aware that Sister had authority to handle

Mother's financial business. Sister continued to write checks on the trust bank account

even after Mother's death in July of 2016.

{¶5} At some point in 2015, Father fell and sustained injuries, was hospitalized,

and eventually placed in a nursing home. Both Brother and Sister agree that after Father

was moved into a nursing home, around the beginning of August 2015, they had

discussions with their parents about constructing an addition onto Sister's home so that

Sister could take care of Mother and Father. Sister and Brother disagree as to whether

their parents were in favor of the addition. Brother claims their parents were against the

idea and Sister represented their parents were on board with it.

{¶6} Nonetheless, in mid-August, Sister signed a contract with a construction

company for the construction of the addition at an original cost of $118,000. Unfortunately,

on September 2, 2015, before the addition was completed, Father passed away.3 Upon

Father's death, Sister became the agent for Mother under Mother's 2014 Power of

3. Brother's lawsuit does not challenge assets that were in Father's name and were transferred to Mother pursuant to the terms of Father's will or his separate revocable living trust.

-3- Warren CA2020-07-036

Attorney.4

{¶7} Following Father's death, Sister took the title to the Lexus to the bureau of

motor vehicles and had the title transferred into Mother's name. Sister continued to pay

Mother's bills using the trust checking account, which included writing checks and paying

off credit card purchases totaling thousands of dollars. Sister also made monetary gifts on

behalf of Mother directly to Brother and his children and indirectly to herself. In addition to

using trust funds to pay for the addition to her home, Sister wrote a check for the purchase

of a boat, alleging it was a gift from her parents.

{¶8} In a letter dated January 27, 2016, Mother resigned as the trustee of her

revocable living trust. The resignation letter indicated that effective February 1, 2016,

Brother and Sister would take over as cotrustees pursuant to the terms of Mother's Trust.

Although he served as cotrustee, Brother admitted he never checked the trust's checking

account transactions as he thought everything Sister was doing was proper. However, after

Mother passed away on July 10, 2016, at age 98, Brother discovered Sister's purchase of

the boat with funds from Mother's trust checking account. Brother became suspicious of

Sister's actions and began to review the trust's records in detail. Upon discovering all of

the credit card charges made during Mother's lifetime, Brother demanded an accounting of

the trust's assets from Sister. Brother contends Sister failed to provide him with an

accounting.

A. Contested Transactions

{¶9} Brother challenges Sister's actions in handling Mother's trust checking

account and the various gifts Sister allegedly made to herself. Brother narrowed down the

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Cite This Page — Counsel Stack

Bluebook (online)
2021 Ohio 4245, 180 N.E.3d 594, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vogel-v-campanaro-ohioctapp-2021.