Gordon v. Reid, 2013 Ohio 3649

Gordon and Reid entered into two land installment contracts in 1997 for properties in Kettering and Dayton, Ohio.
Contracts required Reid to pay real estate taxes and maintain insurance, with tax reimbursements to be made via statements or direct payments by the seller.
Gordon guaranteed no mortgage encumbrances and pledged not to create any after the contract dates.
Reid defaulted on principal and interest; Gordon sought monetary judgments, plus reimbursement for insurance premiums and real estate taxes paid.
The trial court awarded Gordon $14,669.73 for principal and interest and denied tax reimbursements and forced insurance payments.
On appeal, Gordon challenges the laches ruling denying real estate tax reimbursement; the court reverses as to taxes and remands.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether laches bars taxation reimbursement	Gordon argues delay was not unreasonable and prejudice exists.	Reid argues laches bars recovery due to fifteen-year delay and related prejudice.	Laches insufficiently proven; reversal on tax issue; remand for further tax consideration.

Thirty-Four Corp. v. Sixty-Seven Corp., 15 Ohio St.3d 350 (1984) (precludes prejudice from mere accrual of interest or delay when contract terms govern)
State ex rel. Cater v. N. Olmsted, 69 Ohio St.3d 315 (1994) (elements of laches: unreasonable delay, lack of excuse, knowledge, and prejudice)