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Williams v. Ormsby
Supreme Court of Ohio
966 N.E.2d 255 (2012)
In May 2004, Frederick Ormsby (defendant) moved into a house owned by Amber Williams (plaintiff), with whom he had begun a romantic relationship. Ormsby began making mortgage payments on the house and paying property taxes. Eventually, Ormsby paid off the mortgage balance of $310,000, and in exchange, Williams executed a quitclaim deed conveying the house to Ormsby. In March 2005, Ormsby and Williams separated, but continued to briefly cohabitate until Williams moved out. Later that month, Ormsby and Williams executed an agreement whereby the house would be sold and the proceeds allocated among the couple. Shortly thereafter, the couple attempted reconciliation. Williams refused to move back into the house unless Ormsby agreed to grant Williams an undivided one-half interest in the property. In June 2005, Ormsby and Williams signed a second document purportedly making themselves equal partners in the property and providing for the disposition of the house if their relationship ended. Williams returned to the house, and the couple resumed their relationship. The relationship deteriorated again later, and Ormsby moved out of the house. Ormsby and Williams filed separate lawsuits against each other, which the trial court consolidated. Williams sought specific performance of a one-half interest in the property, or alternatively, damages for breach of the contract. Ormsby sought a declaratory judgment that both contracts were void due to lack of consideration. Ormsby and Williams filed separate motions for summary judgment. The trial court granted partial summary judgment to Ormsby, holding that he owned the house exclusively. Williams appealed. The court of appeals reversed, holding that moving into a home with another and resuming a romantic relationship could constitute sufficient consideration to support a contract. The Supreme Court of Ohio granted certiorari to review.
Rule of Law
Holding and Reasoning (Lanzinger, J.)
Concurrence/Dissent (Pfeifer, J.)
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