The Ohio Court of Appeals has upheld a lower court's ruling favoring James V. Propst, the administrator of the estate of James L. Propst, in a legal dispute with Midway Mobile Homes, L.L.C. This case involved claims of breach of contract, conversion, unjust enrichment, and attorneys’ fees related to a mobile home purchase. The court's decision, made on June 8, 2026, is significant for those involved in similar estate and property disputes, as it clarifies the rights of an estate in such situations.
The dispute arose after James Propst entered into a retail installment agreement with Midway for a 1987 mobile home. Following Propst's death in July 2023, his estate sought to settle the remaining balance on the mobile home. However, Midway failed to provide necessary information to the estate and subsequently sold the mobile home to a third party, leading to the legal action.
Background
James L. Propst purchased a 1987 Fleming mobile manufactured home from Midway Mobile Homes on December 1, 2022. The total purchase price was $21,900, with Propst making an $8,760 down payment. He financed the remaining balance through Midway at an 18 percent interest rate. Propst also rented a lot on Midway's property, with rent set to increase in January 2024.
Upon Propst's death on July 10, 2023, all payments on the mobile home were current. Angela Gidden, acting as Propst's power of attorney, notified Midway of his death and requested the payoff information needed to settle the estate. Despite receiving this request, Midway did not provide the necessary information. Instead, the company changed the locks on the mobile home and sold it to another party in June 2024.
The Ruling
The Ohio Court of Appeals, led by Judge Robert J. Patton, affirmed the Girard Municipal Court's ruling in favor of Propst's estate. The court found that Midway had breached the retail installment agreement and wrongfully converted the estate's property. The ruling stated, "the trial court did not err in concluding that Midway breached the retail installment contract because Midway failed to comply with its statutory duties incorporated into the retail installment agreement."
Additionally, the court determined that Midway acted in bad faith by not providing the requested information and disposing of Propst's personal property. The trial court awarded Propst’s estate $14,700 for unjust enrichment and $3,263.54 in attorneys’ fees. The court noted, "The award of attorneys’ fees is discretionary with the trial court," and the evidence supported the trial court's decision.
Impact
This ruling has significant implications for future cases involving estate disputes and mobile home agreements. It reinforces the legal obligations of sellers in retail installment contracts, particularly regarding the rights of an estate following the death of a buyer. The court's decision clarifies that a seller must provide necessary information to the estate, allowing it to fulfill its obligations under the contract.
Moreover, the court's acknowledgment of bad faith in this case may influence how courts view similar disputes in the future. This ruling serves as a reminder that companies must act responsibly and transparently when dealing with customers' estates, especially in situations involving significant assets like mobile homes.
What's Next
Midway Mobile Homes has the option to appeal this decision, but details regarding any potential appeal were not available in the court filing. There are no related cases pending at this time.