LBC Ltd. Partnership v. Stegaman
2017 Ohio 2705
| Ohio Ct. App. | 2017Background
- LBC (Laing) sued tenant Stegaman in Van Wert Municipal Court seeking eviction, unpaid rent and other damages related to a 2013 oral rental arrangement for 209 Westfield Drive; counts for eviction were resolved by agreement and remaining claims were tried March 26, 2014.
- Stegaman counterclaimed for payments owed for windows, doors, legal fees, services rendered, landscaping and other items and amended damages to fit the court’s jurisdictional limit.
- Disputed factual issues at trial included whether Stegaman had earned rent credits for work and expenses, whether he paid rent (or received credits) for several months in 2013, and property condition (trash, carpet, removed water heater).
- Trial court awarded LBC $450 for cleanup costs but awarded Stegaman $450 for window installation; the court found LBC breached the implied warranty of habitability for failing to supply hot water.
- LBC appealed, challenging (1) the damage award to LBC, (2) denial of delinquent rent, and (3) the finding of breach of the warranty of habitability regarding the water heater/removal credit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Adequacy of damage award to LBC for repairs/cleanup | LBC: actual restoration costs exceeded $450; award was insufficient | Stegaman: many claimed costs were unverified or offset by credits; some claims not credible | Trial court’s damage award upheld; no abuse of discretion — judge could find many claimed damages speculative or not credible |
| Entitlement to delinquent rent (Sept–Dec 2013) | LBC: Stegaman did not pay rent while occupying premises, blocking re-rental; LBC entitled to back rent | Stegaman: he performed work and incurred expenses entitling him to rent credits; some payments/credits were accepted by Laing | Trial court’s denial of additional delinquent rent upheld; credibility and credit determinations were within trial court’s discretion |
| Breach of implied warranty of habitability and water heater credit | LBC: parties agreed Stegaman would be credited for purchasing/replacing water heater; LBC should not be liable | Stegaman: landlord knew of lack of hot water, refused repair; purchase was done in reliance on landlord’s assent and tenant entitled to credit/damages | Trial court correctly found breach of warranty of habitability (landlord knew tenant lacked hot water); award and offset reasoning not an abuse of discretion |
Key Cases Cited
- Roberts v. United States Fid. & Guar. Co., 75 Ohio St.3d 630 (Ohio 1996) (trial court’s discretionary damage determinations may rest on credibility and rejection of speculative claims)
- Nationwide Mut. Fire Ins. Co. v. Guman Bros. Farm, 73 Ohio St.3d 107 (Ohio 1995) (questions of law reviewed de novo)
- Sandusky Props. v. Aveni, 15 Ohio St.3d 273 (Ohio 1984) (definition of abuse of discretion as arbitrary, unreasonable, or unconscionable)
- Pembaur v. Leis, 1 Ohio St.3d 89 (Ohio 1982) (abuse of discretion standard requires that no reasonable person could adopt the trial court’s view)
- State v. Adams, 62 Ohio St.2d 151 (Ohio 1980) (discussing standards for appellate review of discretionary rulings)