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Keywords

appealtrialprobateappellantappellee
appealtrialprobatewillappellee

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Masheter v. Boehm, 37 Ohio St.2d 68, 307 N.E.2d 533, 66 O.O.2d 183

Facts

This case originated from an appropriation action brought by the Director of Highways to acquire real property owned by the appellees for the construction of Interstate 90. The appellees operated a job-stamping plant on an acre and a half of land, utilizing various large machinery and equipment that required special foundations and structural measures. The trial court had to determine whether this machinery constituted fixtures that should be included in the compensation for the land taken.

Appellees own an acre and a half of land on which they operate a job-stamping plant for the manufacture of metal components, such as moving parts for machinery. The operation involves the use of a variety of machinery and equipment, some of which is of such great size and weight that its installation requires special foundations, reinforced floors and similar structural measures.

Issue

Whether the machinery and equipment installed on the land constituted fixtures that should be included in the appropriation award.

The primary question in this case, aside from the ultimate question of valuation, is whether this and other machinery and equipment on the premises constituted a part of the real property being appropriated, to be considered in the appropriation award.

Rule

The determination of whether an item is a fixture must be made based on the specific facts of each case, considering factors such as the nature of the property, its annexation to the realty, the purpose of the annexation, and the intention of the annexing party.

The sole fact that machinery and equipment is installed on land or in a structure as a necessary element of an integrated industrial operation does not require that it be taken in an appropriation proceeding.

Analysis

The court analyzed the facts of the case against the established legal principles regarding fixtures. It concluded that the trial and appellate courts had applied an incorrect legal standard by using the assembled-industrial-plant doctrine, which failed to consider the specific circumstances of the case. The court emphasized that the determination of fixture status must be made on a case-by-case basis, taking into account the intention behind the annexation and the relationship between the personal property and the realty.

For reasons set forth below, we find that the trial and appellate courts applied an erroneous test of law to the facts before them in determining the scope of the appropriation, and therefore we must reverse and remand the cause to the Probate Court for reconsideration consistent with this opinion.

Conclusion

The Supreme Court reversed the judgment of the Court of Appeals and remanded the case to the Probate Court for further proceedings consistent with its opinion.

For the foregoing reasons, the judgment of the Court of Appeals is reversed and the cause is remanded to the Probate Court for further proceedings.

Who won?

The prevailing party was the appellant, as the Supreme Court reversed the lower court's decision, ruling that the trial court had erred in its application of the law regarding fixtures.

The central question presented in this case is, at what point will personal property be considered to have become merged with the land or structures on the land appropriated, so that it must be deemed a part of the realty taken, and be compensated for in the condemnation award.

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