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Keywords

appealtrialfiduciarytrustfiduciary dutybreach of fiduciary duty
damagestrialfiduciarytrustsustainedpunitive damagesfiduciary dutybreach of fiduciary dutyunjust enrichment

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Miller v. Stuckey, 42 N.E.3d 304, 2015-Ohio-3819

Facts

Marcene K. Miller, as trustee of the Miller Family Trust, filed a complaint against Dean and Jackie Stuckey, alleging various claims including conversion and breach of fiduciary duty. The dispute arose over quit-claim deeds executed in Florida that transferred property located in Ohio. The trial court ruled that the deeds were invalid under Florida law due to the lack of two subscribing witnesses, despite the deeds being valid under Ohio law.

Marcene, in her individual capacity and as trustee of the Miller Family Trust (the 'Trust'), filed a complaint against the Stuckeys, asserting seven counts: Count One of conversion, Count Two of breach of fiduciary duty, Count Three of 'fraud/fraud in the inducement,' Count Four of undue influence, Count Five of unjust enrichment, Count Six of punitive damages, and Count Seven of invalidity of deed.

Issue

Whether Ohio law or Florida law governs the execution and formal requirements of the quit-claim deeds transferring property from the trust to the Stuckeys.

The issue in this case is whether Ohio law or Florida law governs the execution and formal requirements of the Deeds.

Rule

The law that governs the execution and formal requirements of a conveyance of real property is determined by the law of the situs, which in this case is Ohio, despite the trust's Florida choice-of-law provision.

A transfer of an interest in land is governed by the laws selected by application of the rule in Restatement of the Law 2d, Conflict of Laws, Section 223 (1971).

Analysis

The court applied the Restatement of the Law 2d, Conflict of Laws, which states that the validity of a conveyance is determined by the law of the state where the property is located. Since the property was situated in Ohio, the court concluded that Ohio law applied, which does not require two subscribing witnesses for the validity of the deeds. Therefore, the trial court's ruling that the deeds were void ab initio was erroneous.

The law that would be applied by the courts of the situs of the real property, Ohio, governs the formal, or technical, requirements of the Deeds.

Conclusion

The Court of Appeals reversed the trial court's decision and remanded the case for further proceedings, holding that the quit-claim deeds were valid under Ohio law.

We reverse the judgment of the trial court and remand for further proceedings consistent with this opinion.

Who won?

The Stuckeys prevailed in the appeal because the Court of Appeals determined that the trial court erred in applying Florida law to the deeds, which were valid under Ohio law.

The Stuckeys' assignment of error is sustained.

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