Lyon Revocable Trust v. Berry

Summary

The Ohio Third District Court of Appeals affirmed summary judgment for Trent and Faith Berry in a dispute involving the sale of real estate and alleged agreements to store and relocate personal property. The court held that the fully integrated residential purchase agreement barred the Lyon Trust’s breach-of-contract and unjust-enrichment claims under the parol evidence rule, and that the alleged promise also could not support the fraud claim. The court further held that the conversion claim was duplicative of the contract claim because the Trust sought the same economic damages and failed to establish separate damages.

Holdings

1. The residential purchase agreement was a fully integrated contract, and the alleged contemporaneous personal-property agreement could not be used to vary, contradict, or add to its terms. The breach-of-contract claim was therefore barred as a matter of law.
2. The unjust-enrichment claim was barred because the fully integrated residential purchase agreement governed the same subject matter.
3. The fraud claim failed as a matter of law because the alleged promise to provide storage and moving services directly contradicted an essential term of the fully integrated residential purchase agreement.
4. The conversion claim was properly dismissed on summary judgment because it was functionally indistinguishable from the breach-of-contract claim and sought the same $83,000 economic loss without evidence of separate and distinct damages or an independent duty.

Questions Presented

1. Whether the parol evidence rule barred the Lyon Trust's breach-of-contract claim based on an alleged contemporaneous, unexecuted personal-property agreement.
2. Whether the existence of the fully integrated residential purchase agreement barred the Lyon Trust's unjust-enrichment claim.
3. Whether the alleged promises to store and move personal property could support a fraud claim despite the residential purchase agreement's integration clause.
4. Whether a genuine issue of material fact existed on the conversion claim, including whether the Trust established damages separate and distinct from its contract damages.
5. Whether the trial court properly granted summary judgment to the defendants.

Disposition

affirmed