Link v. Kelly

2025 Ohio 711 · Court of Appeals of Ohio, Third Appellate District · March 3, 2025 · No. 8-24-16

Summary

This Ohio Court of Appeals opinion reviews a trial court's judgment in a dispute over the sale of approximately 120 acres of farmland. The plaintiff-appellant appealed the denial of his motion to enforce a purported settlement agreement and his motion for partial summary judgment seeking specific performance. The appellate court affirmed the trial court's decision, finding insufficient evidence that the defendant's attorney had the authority to bind his client to a settlement without a formal written agreement. The court also addressed several other assignments of error regarding trial court procedures and substantive contract defenses.

Court
Court of Appeals of Ohio, Third Appellate District
Writing for the Court
Miller, J.; Willamowski, J.
Jurisdiction
Ohio
Decision date
March 3, 2025
Docket number
8-24-16
Procedural posture
Appeal from Logan County Common Pleas Court General Division, Trial Court No. CV 21 11 0248
Standard of review
Abuse of discretion for settlement‑agreement issue; de novo for summary‑judgment issue
Precedential value
Published
Parties
Link v. Kelly
Disposition
reversed_and_remanded

Topics

specific performancecontract formationsummary judgmentcontractsreal estate

Practice areas

civil procedurecontractsreal estate

Questions Presented

  1. Whether the trial court erred in denying Link's motion to enforce a settlement agreement.
  2. Whether the trial court erred in denying Link's motion for partial summary judgment on specific performance.

Holdings

  1. The trial court's denial of the motion to enforce the settlement agreement is affirmed.
  2. The trial court erred; summary judgment for specific performance is granted and the judgment of the trial court is reversed and remanded.

Key quotations

“Generally, specific performance can be awarded if there was a valid enforceable contract that was breached.” (¶62)
“A meeting of the minds occurs where ‘a reasonable person would find that the parties manifested a present intention to be bound to an agreement.’” (¶64)

Factual background

Link and Kelly entered into a written purchase agreement on September 3, 2021 for approximately 120 acres of farm land at $988,650. Kelly refused to close the transaction. Link sought specific performance and monetary damages. The parties later discussed a settlement, but the trial court found no enforceable settlement agreement and denied summary judgment on specific performance.

Procedural history

Link filed a complaint alleging a written contract for the sale of ~120 acres of farm land. The trial court denied Link's motion to enforce a settlement agreement and later denied his partial summary‑judgment motion for specific performance. The trial court entered judgment for Kelly. Link appealed.

Remand instructions

Enter judgment for plaintiff‑appellant on his motion for summary judgment on specific performance and proceed with further proceedings on all other pending issues.

Court Document

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