Williams v. Stillion
2017 Ohio 714
| Ohio Ct. App. | 2017Background
- Surface owners (Williams et al.) sued in 2013 seeking to quiet title to a severed three-fourths mineral interest, alleging it had forfeited to them under the 1989 Ohio Dormant Mineral Act (R.C. 5301.56).
- Defendant Ronnie Ray Stillion (trustee of the Charles R. Stillion Family Trust) claimed the trust held fee simple title to the minerals and challenged the constitutionality of the 1989 DMA.
- The Ohio Attorney General intervened to defend the 1989 DMA and later sought summary judgment supporting its constitutionality and self-executing effect.
- The trial court granted summary judgment to Williams, applying only the 1989 DMA and concluding the minerals had vested in the surface owners; the court did not analyze the 2006 DMA.
- The appeal was stayed pending Ohio Supreme Court rulings resolving which DMA version governs claims filed after June 30, 2006; the Supreme Court later held the 2006 DMA controls.
- The Seventh District reversed and remanded, holding the trial court erred by applying the 1989 DMA and directing the trial court to apply the 2006 DMA in the first instance; the court rejected Stillion’s joinder/jurisdiction argument.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Which version of the ODMA (1989 or 2006) governs claims filed after June 30, 2006? | Williams: the 1989 DMA applies and minerals vested by operation of law by 1992. | Stillion: the 2006 DMA governs claims filed after 2006 and its procedures must be followed. | 2006 DMA governs; trial court erred applying 1989 DMA. |
| Was it proper for the trial court to grant summary judgment under the 1989 DMA without addressing the 2006 DMA? | Williams: summary judgment under 1989 DMA was appropriate based on facts and savings period. | Stillion: trial court had to apply the 2006 statute per Ohio Supreme Court precedent. | Reversed: trial court should have considered and applied 2006 DMA. |
| Does framing the complaint as declaratory judgment require joinder of all parties with affected interests (R.C. 2721.12(A))? | Williams: action titled declaratory judgment but substantively a quiet title action; joinder not jurisdictional under quiet-title statute. | Stillion: Eclipse Resources (lessee) was a necessary party and failure to join deprived the court of jurisdiction. | Court held the claim is a quiet-title action (R.C. 5303.01); failure to join Eclipse is not jurisdictional and can be remedied on remand. |
| Are Stillion’s constitutional due-process and savings-event arguments resolved on appeal now that the 2006 DMA applies? | Williams: (argued 1989 statute didn’t violate due process and no savings events occurred) | Stillion: 1989 DMA is unconstitutional and savings events preserved his interest. | Moot: because the 2006 DMA controls, those assignments of error were not addressed and are rendered moot. |
Key Cases Cited
- Bowen v. Kil-Kare, Inc., 63 Ohio St.3d 84, 585 N.E.2d 384 (1992) (standards for appellate remand and trial-court factfinding)
- Hunter v. Shenango Furnace Co., 38 Ohio St.3d 235, 527 N.E.2d 871 (1988) (pleading substance governs over labels)
- State ex rel. The Illuminating Co. v. Cuyahoga Cty. Court of Common Pleas, 97 Ohio St.3d 69, 776 N.E.2d 92 (2002) (courts look to complaint substance, not caption)
- Mills–Jennings, Inc. v. Dept. of Liquor Control, 70 Ohio St.2d 95, 435 N.E.2d 407 (1982) (principles on civil-rule construction and jurisdictions)