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Williams v. Ormsby

Supreme Court of Ohio

966 N.E.2d 255 (2012)

Relevant factsFree

Frederick Ormsby (defendant) moved into a house owned by Amber Williams (plaintiff) during their relationship, paid off the $310,000 mortgage, and received a quitclaim deed making him the owner. After they separated, they signed a March agreement to sell the house and split the proceeds. Attempting reconciliation, Williams refused to move back unless given a half interest, so in June they signed a second document making them equal partners; she returned, but the relationship again failed. Each sued the other; Williams sought a half interest or damages, while Ormsby sought a declaration that both contracts were void for lack of consideration. The trial court gave Ormsby sole ownership; the court of appeals reversed, finding resuming the relationship could be consideration; the Ohio Supreme Court granted review.

IssueFree

Whether moving into another person's home to resume a romantic relationship is sufficient consideration to support a contract granting the moving person an ownership interest in the home.

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