Williams v. Ormsby, 131 Ohio St. 3d 427

Amber Williams and Frederick Ormsby, nonmarital couple, cohabitated at Amber’s Hardwood Hollow home after he moved in May 2004; Frederick paid mortgage and taxes, ultimately paying about $310,000, and Amber deeded him title via quitclaim in December 2004.
Following planned marriage, they separated in March 2005, obtained restraining order, then signed March 24, 2005 to sell the home and divide proceeds.
Two months later, they reconciled with a June 2005 document claiming they were equal partners and redefining ownership and duties, while Amber returned to living with Frederick.
By April 2007 they lived separately within the home; Amber ended the relationship in September 2007; Frederick left in April 2008.
The cases below originated in trial court, which granted summary judgment on March 2005 as to consideration, and compelled title to Frederick; Ninth District reversed, prompting discretionary review by this court.
The central issue is whether resuming a romantic relationship by moving in together constitutes legally cognizable consideration for a contract.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is moving in together a valid consideration for a contract?	Williams argues June 2005 contract was supported by consideration.	Ormsby argues love/affection is not valid consideration.	No; love/affection alone is not consideration.
Did the June 2005 document constitute a valid novation of the March 2005 agreement?	Williams contends June 2005 superseded March 2005 by novation.	Ormsby contends no valid novation due to lack of new contract with consideration.	Not a valid novation; June 2005 lacks consideration.
Do Ohio law principles permit enforcement of contracts based on romantic relationships or cohabitation?	Williams relies on cited cases suggesting relationship can be contract consideration.	Ormsby argues such consideration is insufficient and contrary to precedent.	Love/affection alone cannot support a contract; these cases do not create palimony.

Carlisle v. T&R Excavating, Inc., 123 Ohio App.3d 277 (9th Dist. 1997) (recognizes love/affection not valid consideration; gift motive)
Snyder v. Warde, 151 Ohio St. 426 (Ohio 1949) (services in a will context; not altering statute of frauds; ordinary services typically money‑compensable)
Roccamonte, 174 N.J. 381 (199? (2002)) (New Jersey palimony; not adopted in Ohio)
Flanders v. Blandy, 45 Ohio St. 108 (1887) (love/affection alone not consideration; gift doctrine)
Judy v. Louderman, 48 Ohio St. 562 (1891) (consideration must be bargained for; not merely motive)
Hotels Statler Co., Inc. v. Softer, 103 Ohio St. 638 (1921) (courts do not inquire into adequacy of consideration)