Mapes v. Gibbs

Summary

The Fourth District Court of Appeals of Ohio affirmed an Adams County Court judgment granting Joyce Mapes possession of rental property in a forcible entry and detainer action and denying Ewing “Toby” Gibbs’s counterclaim concerning an alleged land contract. The court held that the county court had subject-matter jurisdiction to consider the counterclaim seeking equitable enforcement of the alleged land contract and that the county court’s $15,000 monetary limit did not apply. The court overruled Gibbs’s assignment of error challenging the denial of his motion to transfer the case to the court of common pleas.

Holdings

1. An Ohio county court has subject-matter jurisdiction to adjudicate a forcible entry and detainer action and a related counterclaim involving equitable enforcement of an alleged land contract when the counterclaim seeks equitable relief rather than a monetary amount exceeding the county court's jurisdictional limit.
2. The trial court did not err in denying Gibbs's motion to transfer because the county court had subject-matter jurisdiction over both the forcible entry and detainer action and the related land-contract counterclaim.

Questions Presented

1. Whether the Adams County Court had subject-matter jurisdiction over the forcible entry and detainer action and Gibbs's counterclaim seeking enforcement of an alleged land contract.
2. Whether the counterclaim required certification or transfer of the action to the Adams County Court of Common Pleas because of the amount or nature of the claimed property interest.
3. Whether the trial court erred by denying Gibbs's motion to transfer and granting Mapes's forcible entry and detainer claim.

Disposition

affirmed