Snapp v. Castlebrook Builders, Inc.
7 N.E.3d 574
Ohio Ct. App.2014Background
- Snapp sued Castlebrook and Kappeler for CSPA violations, fraud, and unjust enrichment over a 2008–2009 home renovation project.
- Castlebrook was a Delaware? no, Ohio corporation owned by Kappeler; Kappeler and Castlebrook were sued personally and as alter ego.
- Trial involved extensive billing disputes, missing documentation, and allegations of double/triple charges and improper charges.
- Jury found Castlebrook violated CSPA (knowing), and found liability for fraud and unjust enrichment; piercing the veil against Kappeler.
- Post-trial, the court awarded treble damages and attorney’s fees under the CSPA; final judgment affirmed on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Piercing the corporate veil standard applied | Belvedere standard satisfied | Standard misapplied; misuse of LeRoux | Belvedere three-prong standard applied correctly |
| Treble damages and attorney fees under CSPA | AG rule or court decision supported trebling | No prior rule/decision found | Judgment to treble damages and award attorney fees upheld |
| Consistency and weight of verdicts | Damages supported by evidence | Inconsistencies in verdicts | Verdit consistent; not against weight of evidence |
Key Cases Cited
- Belvedere Condominium Unit Owners' Assn. v. R.E. Roark Cos., Inc., 67 Ohio St.3d 274 (1993) (establishes three-part piercing standard)
- Dombroski v. WellPoint, Inc., 2008-Ohio-4827 (Ohio Supreme Court) (piercing rare; strict limits; alter ego)
- LeRoux's Billyle Supper Club v. Ma, 77 Ohio App.3d 417 (1991) (early piercing framework; cited in Belvedere lineage)
- North v. Higbee Co., 131 Ohio St.507 (1936) (abrogated strict form of fraud-based piercing (North standard))
- Goodyear Tire & Rubber Co. v. Aetna Cas. & Sur. Co., 95 Ohio St.3d 512 (2002) (affirms evidentiary standard for directed verdict; probative value test)