The Ohio Court of Appeals has reversed a lower court's decision that dismissed claims from Tonti Homes Corporation against Tom Siculan and others. This ruling, issued on May 28, 2026, affects how trusts are recognized in Ohio law and could have implications for future real estate transactions involving trusts.
Tonti Homes filed its complaint in December 2020, alleging that Siculan had improperly managed property held in a blind trust. The court's ruling is significant as it clarifies the legal standing of trusts in Ohio, particularly regarding the term 'blind trust,' which had raised questions in the initial court proceedings.
Background
Tonti Homes Corporation, the plaintiff in this case, is a real estate company that purchased six lots of land in 1991. Two of these lots were deeded to Tom Siculan, who was designated as the trustee of a blind trust. Tonti Homes claimed that Siculan acknowledged he did not own the lots and was merely holding them in trust pending annexation proceedings.
However, in May 2019, Siculan sold the lots to other parties, including Jessica Perez Manrique and William Perez Bernal, without Tonti Homes' consent. This led Tonti Homes to file a lawsuit against Siculan and the other defendants, alleging various claims including breach of fiduciary duty and fraud.
The case reached the Franklin County Court of Common Pleas, where the court dismissed Tonti Homes' claims related to the blind trust, arguing that Ohio law does not recognize such trusts. Tonti Homes appealed this decision, leading to the recent ruling from the Ohio Court of Appeals.
The Ruling
The Ohio Court of Appeals, led by Judge Boggs, found that the lower court erred in dismissing Tonti Homes' claims. The court ruled that the facts presented in Tonti Homes' complaint were sufficient to allege the creation of a trust, stating, "accepting the claims in the plaintiff’s complaint as true, the Court can only conclude that the plaintiff’s claims based on the creation of a 'blind trust' between it and Siculan fail to state a claim upon which relief can be granted."
The appellate court emphasized that Tonti Homes had provided evidence, including a letter from Siculan affirming he was holding the property in trust. The court stated that the term 'blind trust' should not be a barrier to recognizing the trust's existence. The ruling reversed the lower court's decision and remanded the case for further proceedings.
Impact
This ruling has significant implications for real estate law in Ohio. It clarifies that the term 'blind trust' does not negate the existence of a trust if the underlying facts support its creation. This decision may encourage other plaintiffs to pursue claims involving trusts that may have previously been dismissed due to similar terminology issues.
Moreover, the ruling could influence how real estate transactions are conducted in Ohio, especially regarding the management of properties held in trust. It reinforces the notion that the intentions of the parties involved in establishing a trust are critical, regardless of the specific language used to describe it.
What's Next
Tonti Homes' case will return to the Franklin County Court of Common Pleas for further proceedings consistent with the appellate court's ruling. It remains to be seen if the defendants will seek to appeal this decision or if any related cases will arise from this ruling.