Dudley v. Dudley, 2019 Ohio 4309

Brothers Thomas and Terry Dudley each owned half of three real-property parcels in a partition action.
The parties entered a court‑approved settlement: the Property would be sold at public auction on or before March 1, 2018, with closing "on or before 45 days after auction."
Auction occurred March 1, 2018; Buyers (Terry and Katherine Dudley) were the successful bidders and agreed to pay $585,000, with closing "on or before Friday April 20, 2018."
Disputes arose about closing timing and a requested price adjustment for the Ringwood parcel (alleged to be ~5 acres short); Buyers moved on June 13, 2018 to compel closing and for an equitable price adjustment.
Trial court denied the price adjustment, granted the motion to compel closing, ordered closing by January 31, 2019, and designated April 1, 2018 as the retroactive effective closing date.
Sellers appealed only the retroactive closing‑date designation, arguing it deprived them of farm income; the Twelfth District affirmed because Sellers failed to provide a transcript or record showing error, so the court presumed regularity of the lower‑court proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by designating a retroactive closing date of April 1, 2018	Sellers: retroactive date deprived them of substantial farm income and was improper	Buyers: they were ready, willing, and able to close and incurred financing costs; closing should be compelled	Affirmed. Appellants failed to supply transcript/record to show error; appellate court presumed regularity and declined to overturn the trial court

Knapp v. Edwards Laboratories, 61 Ohio St.2d 197 (1980) (appellant bears burden of showing error by reference to matters in the record)