Steiner v. Piero-Silagy, 2017 Ohio 7669

In 1985 Vicki Steiner bought a 12.09‑acre lot and later built a home; after divorce she refinanced and held title alone.
In August 2011 Steiner refinanced and obtained two loans; at closing she and her mother, Delores Houchin, signed a quitclaim deed placing both names on title, recorded as tenants in common.
Houchin later was declared incompetent and a guardian (appellee) was appointed; the guardian claimed Houchin had an ownership interest.
Steiner filed an action to quiet title in 2016, asserting the 2011 deed was only to accommodate the lender and that she alone should hold equitable and legal title.
At bench trial the court found the deed unambiguous, no evidence showed coercion by the lender, Houchin’s signature made her a tenant in common, and Steiner failed to prove grounds for a constructive trust. Judgment for appellee; Steiner appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Steiner was entitled to summary judgment quieting title	Steiner: deed was executed only as an accommodation to the lender; no intent to convey ownership, so summary judgment should follow	Guardian: deed is facially valid; factual disputes exist about intent and consideration	Denied as moot after trial; trial showed genuine factual disputes supporting guardian
Whether the quitclaim deed conveyed a one‑half interest to Houchin	Steiner: despite signing, she did not intend to give a half interest; she felt pressured and expected no ownership transfer	Guardian: voluntary signing and deed language created tenancy in common; Houchin provided consideration by cosigning and extending credit	Court: deed unambiguous; presumption that deed reflected parties’ intent not rebutted; Houchin is a tenant in common
Whether coercion/duress by lender invalidated the deed	Steiner: bank required Houchin on title, so signing was under compulsion	Guardian: no evidence from the lender that signing was required; Steiner had alternatives	Court: no evidence of coercion from lender presented; no basis to void deed
Whether a constructive trust should be imposed	Steiner: equitable relief (constructive trust) warranted because she did not intend transfer	Guardian: no clear and convincing evidence to impose trust; Houchin incurred liability and provided consideration	Court: Steiner failed to produce clear and convincing evidence; constructive trust denied

Continental Ins. Co. v. Whittington, 71 Ohio St.3d 150 (holding that denial of summary judgment can be harmless if trial shows genuine issues of material fact)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (standard for abuse of discretion)
State v. Martin, 20 Ohio App.3d 172 (weight-of-evidence standard for review)
State v. Thompkins, 78 Ohio St.3d 380 (definition/explanation of weight of the evidence)
Eastley v. Volkman, 132 Ohio St.3d 328 (presumption in favor of trial court’s factual findings)
American Energy Corp. v. Datkuliak, 174 Ohio App.3d 398 (deed construction: courts presume deed expresses parties’ intent and cannot contradict clear deed language)
University Hospitals of Cleveland, Inc. v. Lynch, 96 Ohio St.3d 118 (party seeking constructive trust must show clear and convincing evidence)
Ferguson v. Owens, 9 Ohio St.3d 223 (definition and equitable purpose of constructive trust)