Ohio Assembly Enacts Shift in Receivership Environment after Six Decades of Inactivity

Reprinted with permission from author Christopher D. Caspary, Staff Attorney, Cuyahoga County Court of Common Pleas. 
(This article was originally printed in the September 2015 Cleveland Metropolitan Bar Journal)


            The last time the Ohio Assembly modified Ohio Revised Code (“R.C.”) §2735, Dwight D. Eisenhower was President, a gallon of gasoline cost twenty cents, and Mickey Mantle was in his third season as the starting centerfielder of the New York Yankees.

Moving beyond mere facilitation of judgment collection, the receivership remedy has evolved into a common, expedient, and generally cost-effective means to effectuate a defunct company’s dissolution or resolve ongoing issues within an insolvent organization. Due to these developments, R.C. §2735, the cornerstone of Ohio receivership law, was in drastic need of revision and expansion.

            Due to a patch-work of court decisions addressing issues that were not covered by statute or existing precedent, certain crucial aspects of receivership law were subject to conflicting interpretations. A statutory framework was needed to help standardize results in receivership actions. The current amendment to R.C. §2735 in House Bill 9 (“H.B. 9”) codifies certain best practices that are familiar in Cuyahoga County without restraining the court’s ability to appropriately tailor relief and receivership orders.

The Law

            H.B. 9 was enacted December 19, 2014 and has an effective date of March 23, 2015. Though the changes present in H.B. 9 are extensive, the legislature did not modify R.C. §2735.03 (Oath and Bond), R.C. §2735.05 (Examination), or R.C. §2735.06 (Investment of Funds by Receiver). 

Key Changes to R.C. §2735

·         R.C. §2735.01(C) expounds upon §2735.01(A)(6), which combine to specify that receivers “may be appointed to manage all the affairs” of the applicable business entity.

·         R.C. §2735.04(B) codifies substantive powers of the receiver such as entering into lease or sale contracts that do not impact lien priority, executing construction contracts, and conveying real or personal property. The subsection also authorizes the commonplace practice of opening a deposit account.

·         R.C. §2735.04(C) codifies and potentially expands upon existing case law on lien priority for receiver fees and expenses. See, e.g., Dir. of Trans. of Ohio v. Eastlake Land Dev. Co., 177 Ohio App. 3d 379, 388-389, 2008-Ohio-3013, 894 N.E.2d 1255 (8th Dist.) (allowing expenses from a mortgage sale to extinguish receivership fees with mortgagee acquiescence and full participation in the matter); see also, Ohio v. Tokmenko, 112 Ohio App. 42, 43, 165 N.E2d 804 (8th Dist. 1960) (noting that receivership expenses are generally payable out of the “corpus of the property”); but see, Wilkens v. Boken, Inc., 8th Dist. Cuyahoga No. 64230, 1993 Ohio App. LEXIS 6202, ¶ 16-19 (Dec. 23, 1993) (requiring that “unusual or substantial” expenditures provide notice, an opportunity to be head, and receive eventual court approval).

·         R.C. §2735.04(D) definitively establishes a comprehensive procedure allowing a receiver to dispose of real property.

·         R.C. §2735.04(D)(1)(a) and §2735.04(D)(3) codify existing case law on a receiver’s ability to sell property “free and clear of liens” (with limited exceptions). See Huntington Nat’l Bank v. Motel 4 BAPS, Inc., 191 Ohio App. 3d 90, 94-95, 2010-Ohio-5792, 944 N.E.2d 1210 (8th Dist.).

·         R.C. §2735.04(D)(1)(b)-(c) allows the court to order the receiver to provide evidence of the value of the property or solicit and consider additional offers prior to executing a conveyance.  
·         R.C. §2735.04(D)(2) sets forth specific procedures that must occur before a receiver can dispose of real property. This subsection specifically requires that the receiver file a motion with the court regardless of whether a specific offer to purchase has been received and provide at least ten-day written notice to all interested parties (defined in the Statute). If an objection is filed, a hearing must take place that allows all parties to be heard. Finally, an order of sale must be issued by the court.

·         R.C. §2735.04(D)(7) requires that the court create a redemption deadline allowing a party to act and void the sale. This period cannot be shorter than three days.

·         R.C. §2735.04(D)(10) requires that the receiver file and serve a certificate of sale and report that outlines important transactional details for property conveyance conducted under the auspices of R.C. §2735.04(D)(2)(a)(ii), which governs sales with a specific offer to purchase the real property in question. This allows a receiver to avoid having to obtain court approval for a contract sale twice.

Observations and Challenges Moving Forward

·         Receivership case law in Ohio remains dynamic and growing, yet at times, incomplete.

·         The most substantial amendment found in H.B. 9 addresses the disposition of real property by a receiver and the ability to do so “free and clear of liens.” Property rights can be difficult to protect in the current bad asset environment, where title reports are complicated, lengthy, and at times inaccurate.

·         R.C. §2735.04(D)(2)(b) sets forth notice requirements that must be met before a receiver can dispose of real property. The statute notes that either a preliminary judicial report or a title commitment is acceptable for determining the parties that must be noticed.

·         Case law interpreting the changes present in H.B. 9 will take time to fully develop. Although the amendment codifies important receivership precedent, certain gap-filling decisions were not specifically addressed by the General Assembly, and their continued applicability may be in question. For example, though R.C. §2735.04(C) empowers the court to “require an additional deposit” (to be deposited by the requesting or consenting parties) “to cover funds” that will be expensed pursuant to a R.C. §2735.04(B)(4) contract, the Statute does not specifically address whether a court can require the original movant (or acquiescing and full participating party) to cover all receivership costs not extinguished by the receivership estate.  
·         R.C. §2735.02 adds language that a court should afford “priority consideration…to any of the qualified persons nominated by the party seeking the receivership,” but cautions that “[n]o nomination of qualified persons for the receivership is binding upon the court.” Though the Statute is clear that the court retains ultimate discretion in deciding who to appoint, the law now views receiver nominations by the movant favorably.

·         Whether courts, in interpreting R.C. §2735.04(C), will maintain the aforementioned “unusual or substantial” standard for expense authorization and priority despite such a distinction not being present in the Statute.


            The amendment of R.C. §2735.01 et seq. provides needed statutory guidance and predictability to the  receivership environment and is a net positive for receivership practitioners as the lack of predictability in receivership orders was one of the largest disadvantages when utilizing state court remedies. The amendment specifically codifies certain receivership powers that have become commonplace in many jurisdictions, such as disposing of real property “free and clear of liens,” scheduling hearings and allowing an opportunity to be heard before entering certain receivership orders, and creating a blanket rule of receivership fee and administrative expense priority.

            H.B. 9 does not inhibit the ability of the court to tailor the order appointing a receiver to the specific facts of the matter at hand and allows the receivership remedy to continue to be an important, powerful, and flexible resource available for attorneys in bad asset liquidation or business salvage environments. Mickey Mantle would be proud; the General Assembly has just hit a homerun. 

Disclaimer: The contents of this article are not intended to serve as legal advice. Appropriate legal counseling or other professional consultation should be obtained prior to undertaking any course of action related to the topics explored by this article.

Christopher D. Caspary serves as the Staff Attorney to Judge Nancy A. Fuerst in the Cuyahoga County Court of Common Pleas. Mr. Caspary completed his undergraduate studies at The Ohio State University and received his JD/MBA from Cleveland State University. Mr. Caspary has an interest in the diverse area of business law. 

Ohio Supreme Court Upholds NEORSD's Stormwater Management Program

On September 15, 2015, the Ohio Supreme Court issued its long awaited decision in Northeast Ohio Regional Sewer Dist. v. Bath Twp., Slip Opinion No. 2015-Ohio-3705, and found in favor of the sewer district. The Northeast Ohio Regional Sewer District (“NEORSD”) is a sewer district created under Revised Code Chapter 6119 and services 61 communities in and around Cuyahoga County.  It sought in 2010 to implement a regional stormwater management program in the communities it services.
In connection with the program, NEORSD assessed fees on every parcel within its service district. The fees were based upon the amount of impervious surface located on each parcel. An impervious surface is one that does not permit the absorption of fluids; typically, artificial structures such as pavement covered by asphalt, concrete, brick and stone, as well as rooftops.
After NEORSD adopted its stormwater management program, it filed a declaratory action in the Cuyahoga County Court of Common Pleas to confirm its authority to establish the program and assess fees on property owners located in its service area. The trial court affirmed NEORSD’s authority to implement the stormwater management program and to assess fees on property owners.  Affected communities and several large property owners appealed, and the Ohio Court of Appeals overturned the trial court decision.  Prior to the Court of Appeals’ reversal, NEORSD had collected approximately $20 million in fees, which it placed into escrow pending its appeal to the Ohio Supreme Court.
The Ohio Supreme Court addressed 2 issues in its decision: (1) whether NEORSD’s stormwater management program is authorized by statute and by its charter, and (2) whether the related fee structure is authorized by statute and its charter. The court found both the plan and the fee structure to be authorized by statute and NEORSD’s charter.
The answer to (1) hinged on the definition of “waste water” which is defined in in R.C. 6119.011(K) as “any storm water and any water containing sewage or industrial waste or other pollutants or contaminants derived from the prior use of the water.”  The appellees and the Court of Appeals interpreted “waste water” to necessarily mean “water containing waste” and that any storm water would only constitute “waste water” when it is combined with sewage or pollutants.  The Ohio Supreme Court interpreted the statute more expansively to indicate that “waste water” comes in two forms, “any storm water” and “any water containing sewage or industrial waste or other pollutants or contaminants derived from the prior use of the water.”
The latter interpretation, as determined by a majority of the Ohio Supreme Court justices, is understandable from reading the text of the statute but is much more expansive in its application than the narrower reading held by the Court of Appeals, and will provide regional sewer districts with a broader reach in their authority.
In determining the second issue regarding fee collection, the Ohio Supreme Court held that while NEORSD currently does not own or operate the various parts of the current stormwater-management system, a “water resource project” includes facilities “that are to be acquired, constructed or operated” by NEORSD. and therefore it may assess fees for this purpose under the statute.   The court left the door open for future challenges if NEORSD fails to use the fees it collects to acquire, construct or operate a facility that will be part of the regional stormwater-management system. 
Some of the justices on the Ohio Supreme Court raised intriguing dissents regarding NEORSD’s fees as not being authorized by the statute or being structure as a tax masquerading as a fee.

However, neither dissent won over a majority of the court’s justices and NEORSD’s ability to assess fees under its stormwater management plan remains intact.
Now that the Ohio Supreme Court has affirmed NEORSD’s authority to implement the stormwater management plan and assess related fees, NEORSD has indicated it will request that funds be released from the escrow so it can begin implementing stormwater projects.  NEORSD further stated on its web site that it will take time to review the court’s decision and establish a plan for reorganizing and re-implementing its stormwater management plan before any fees are assessed against property owners in the future.
This decision will, in the short term, only impact the 61 communities that are part of NEORSD’s service area.  However, now that the authority to implement such programs has been upheld by Ohio’s highest court, other regional sewer districts in the State of Ohio may follow suit.
Commercial properties, health care facilities and multi-family projects are some the properties that will be the hardest hit by this decision as these types of projects typically have large areas of impervious surfaces. These higher costs will likely be passed along to tenants in higher rents and to customers/clients in higher prices or fees. It’s only money, right?

Recent Real Estate Legislation Introduced in the Ohio Legislature

Recent bills of the 131st General Assembly  (See https://www.legislature.ohio.gov/) pending in the Ohio House and Ohio Senate related to real property are as follows:

HB 134 - https://www.legislature.ohio.gov/legislation/legislation-status?id=GA131-HB-134

To amend sections 323.47, 1901.18, 1901.185, 2303.26, 2329.01, 2329.02, 2329.20, 2329.21, 2329.23, 2329.26, 2329.30, 2329.31, 2329.33, 2329.52, and 2909.07 and to enact sections 2308.01 to 2308.04, 2329.211, and 2329.311 of the Revised Code to establish summary actions to foreclose mortgages on vacant and abandoned residential properties and to make other changes relative to residential foreclosure actions. Status- Referred to Local Government Committee.

To amend sections 3745.13 and 4745.01 and to enact sections 3744.01, 3744.02, 3744.03, 3744.04, 3744.06, 3744.09, 3744.12, 3744.13, 3744.15, 3744.16, 3744.17, 3744.18, 3744.20, and 5302.31 of the Revised Code to provide for the remediation of real property on which an illegal methamphetamine manufacturing laboratory has been discovered. Status- Referred to Judiciary Committee.

HB 149 - https://www.legislature.ohio.gov/legislation/legislation-summary?id=GA131-HB-149

To amend sections 4112.02, 4112.05, 4112.08, and 4112.14 and to enact section 4112.024 of the Revised Code to make permissive actual damages and attorney's fees, to limit certain civil penalties, to allow respondents to recover attorney's fees in certain instances, and to exempt certain landlords from the housing provisions of the Ohio Civil Rights Law. Status- Referred to Financial Institutions, Housing, and Urban Development Committee.

To amend sections 1509.02, 1509.071, 1509.11, 1509.34, 1509.50, 1513.08, 1513.182, 1514.11, 5747.98, 5749.01, 5749.02, 5749.06, 5749.11, and 5751.01 and to enact sections 164.29, 190.01, 190.02, 190.03, 190.04, 190.05, 321.50, 321.51, 505.96, 1509.075, 3737.15, 3745.50, 5501.37, 5747.56, 5747.63, and 5749.18 of the Revised Code to change the basis, rates, and revenue distribution of the severance tax on oil and gas, to create a grant program to encourage compressed natural gas as a motor vehicle fuel, to authorize an income tax credit for landowners holding an oil or gas royalty interest, and to exclude some oil and gas sale receipts from the commercial activity tax base. Status- Referred to Ways and Means Committee.

To amend sections 715.72, 715.79, 715.80, 715.81, 715.82, 715.83, 5709.61, 5709.62, 5709.63, 5709.632, 5709.82, 5733.06, 5733.41, 5747.02, and 5747.41 and to repeal sections 715.73, 715.74, 715.75, 715.76, 715.761, 715.77, 715.771, and 715.78 of the Revised Code to revise the law governing the creation and operation of joint economic development districts (JEDDs) and enterprise zones. Status- Referred to Economic and Workforce Development Committee.

To amend sections 5311.18 and 5312.12 of the Revised Code to provide that a portion of a condominium or planned community assessment is prior to other liens on condominium units and planned community lots and to provide that a condominium unit owner’s association lien is a continuing lien. Status- Referred to Commerce and Labor Committee.

To amend section 5715.19 of the Revised Code to require counties, municipal corporations, townships, and school boards that file complaints against the valuation of property they do not own to pass a resolution approving the complaint and specifying the compensation paid to any person retained to represent the county, municipal corporation, township, or school board in the matter of the complaint. Status- Referred to Local Government Committee.

To amend sections 133.04, 133.06, 709.024, 709.19, 3317.021, 5501.311, 5709.12, 5709.82, 5709.83, 5709.831, 5709.832, 5709.85, 5709.91, 5709.911, 5709.913, and 5715.27 and to enact sections 1710.14, 1724.12, 5709.45, 5709.46, and 5709.47 of the Revised Code to authorize municipal corporations to create downtown redevelopment districts and innovation districts for the purposes of promoting the rehabilitation of historic buildings, creating jobs, encouraging economic development in commercial and mixed-use areas, and supporting grants and loans to technology-oriented and other businesses. Status- Referred to Government Accountability and Oversight Committee.

To amend section 5120.092 and to enact section 5120.80 of the Revised Code to allow the Director of Budget and Management to transfer funds from the Adult and Juvenile Correctional Facilities Bond Retirement Fund to any fund created in the state treasury administered by the Department of Rehabilitation and Correction or the Department of Youth Services, to create the Community Programs Fund, and to authorize the conveyance of state-owned real property. Status- Referred to House Government and Accountability Committee.

HB-273 – https://www.legislature.ohio.gov/legislation/legislation-summary?id=GA131-HB-273

To amend sections 1923.12, 1923.13, and 1923.14 and to enact section 4781.56 of the Revised Code regarding the removal of abandoned or unoccupied manufactured homes, mobile homes, or recreational vehicles from manufactured home parks. Status- Legislation introduced.

To amend section 2323.13 of the Revised Code to require notice and an opportunity for a hearing to a defendant before entry of judgment pursuant to a confession of judgment. Status- Legislation introduced.

To amend sections 307.699, 3735.67, 5715.19, 5715.27, and 5717.01 of the Revised Code to limit the right to initiate most types of property tax complaints to the property owner and the county recorder of the county in which the property is located. “The board of county commissioners, the prosecuting attorney or treasurer of the county, the board of township trustees of any township with territory within the county, the board of education of any school district with any territory in the county, or the mayor or legislative authority of any municipal corporation with any territory in the county may file such a complaint only as a counterclaim to a complaint filed by the property owner, the property owner's spouse, or an individual retained by the property owner or the property owner's spouse who is authorized to file a complaint under this section.” Status- Referred to Ways and Means Committee.

SB 96 - https://www.legislature.ohio.gov/legislation/legislation-summary?id=GA131-SB-96

To amend section 5715.39 of the Revised Code to waive any penalty due with respect to unpaid property taxes resulting when a mortgage lender fails to notify the county auditor of a satisfied mortgage. Status- Referred to State and Local Government Committee.

SB 201- https://www.legislature.ohio.gov/legislation/legislation-summary?id=GA131-SB-201

To amend section 3767.01 of the Revised Code to expand nuisance law to apply to any real property, including vacant land, on which an offense of violence has occurred or is occurring. Status- Legislation introduced.

Dower Rights Effect on the Transfer of Real Property

If you are married and go to transfer real property or mortgage real property, your spouse will be asked to sign a release of his or her ‘dower rights.’ Dower rights are the interest that a person has in real property owned by his or her spouse.  If one person owns property during a marriage, his or her spouse has a 1/3 life estate interest in that property.   Usually this interest comes up in the context of a will of a deceased party, where the surviving spouse has the right to elect his or her dower interest in lieu of what is provided in the will.  However, the existence of this right also comes into play with certain real estate transactions.

Only a small handful of states, maybe 3-4, still have dower rights codified in their law and Ohio happens to be one of them.  The basic provisions for dower in Ohio are found in Chapter 2103 of the Revised Code. The current statute was passed back in 1953 but has been amended from time to time since. Under Ohio law, unless voluntarily released and subject to a few qualifications for special circumstances, death or divorce are the only two ways to terminate dower rights.

What this means when a married individual wants to transfer real property that he or she owns in his/her own name, a release of dower rights signed by the grantor’s spouse will be included in the deed.

Many mortgage lenders will also want a borrower’s/guarantor’s spouse to release dower rights in connection with the mortgage loan. Some spouses are hesitant to sign a release under the mistaken impression that it somehow obligates them on the mortgage. Merely releasing mortgage rights does not obligate the spouse on the loan. Lenders want to know that if they have to foreclose on the mortgage and take title to the property that they will have clear title to the property.
So the next time you go to transfer real property and you are asked to obtain your spouse’s signature on the deed, you will know why.

No Comma, No Judgment for Plaintiff

(Watch your Language with Statutes and Ordinances; Grammar Counts)

As established in other “Watch Your Language” articles for this Blog, as a general rule, courts will uphold language in commercial agreements, unless it is contrary to statutory law or public policy. Because of this judicial deference to “commercial language”, you must say what you mean, precisely, or a judge will decide what you meant. Compounding the problem is the fact that courts typically refuse to consider extrinsic evidence of a party’s intent (offered by such party) if they determine the contract language is clear and unambiguous. What is said within the “four corners of the agreement” is simply deemed the best evidence of intent.  Even the failure to follow a seemingly trivial grammar rule (the use of i.e. vs. e.g.) can result in unintended consequences. In a 1995 Connecticut case, in spite of the tenant’s verbalized intent to the contrary, the court held that the use of “i.e.” [meaning, that is] vs. e.g. [meaning, for example] preceding a short list of repair items in a lease served to limit landlord’s structural responsibility to only those items listed in the lease vs. merely providing examples of the same.

Saying what you mean, precisely, is as important in drafting statutes and ordinances as it is in commercial agreements. As a general rule, courts will also uphold clear and unambiguous statutory language.Statutes clear in their terms need no interpretation; they simply need application. If the inquiry into language of a statute reveals that the statute conveys a meaning which is clear, unequivocal and definite, at that point the interpretative effort is at an end, and the statute must be applied accordingly." Provident Bank v. Wood (1973), 36 Ohio St. 2d 101, 105-106.

The Village of West Jefferson recently discovered these axioms (“what is written = what is intended” and “grammar counts”) the hard way, in W. Jefferson v. Cammelleri, 2015-Ohio-2463, a 12th District Ohio Court of Appeals case that was decided on the basis of the lack of a comma.

In Cammelleri, Defendant-appellant, Andrea Cammelleri’s pickup truck was towed from a parking space in front of her house, and impounded. Cammelleri was cited for violating West Jefferson Codified Ordinance Section 351.16(a), which states: “It shall be unlawful for any person to park upon any street in the Village, any motor vehicle camper, trailer, farm implement and/or non-motorized vehicle for a continued period of twenty-four hours …” Ms. Cammelleri contested the citation, and in March, 2014, the matter proceeded to trial.

At trial, Cammelleri argued that the ordinance did not apply because the language prohibits a “motor vehicle camper” from being parked on the street for an extended period of time, and a truck is not a motor vehicle camper.  The village contended that the actual wording of the ordinance did apply because a comma was inadvertently omitted between the phrase "motor vehicle" and the word "camper."   The trial court found for the village, holding that when reading the ordinance in the context of its intent, it applied to motor vehicles and campers, and "anybody reading [the ordinance] would understand that it is just missing a comma.

On appeal to the 12th District Ohio Court of Appeals, Ms. Cammelleri repeated the argument she made to the trial court, namely that her pickup truck was not subject to the ordinance, because her pickup truck does not constitute a “motor vehicle camper” as identified by the ordinance.

The village argued that because of an unintended clerical error, a comma was missing between the phrase "motor vehicle" and the word "camper," and consequently, the ordinance should apply, as intended to Cammelleri's pickup truck as a motor vehicle. 

The 12th District Court of Appeals agreed with one tenet acknowledged by both parties; that when called on to interpret statutes and ordinances, “the paramount concern is determining legislative intent in enacting the statute.”

However, the court emphasized that the basic rules for statutory interpretation (in effect, “what is written = what is intended” and “grammar counts”) should apply.  According to the court, “[we must] discern this intent by looking at the language used in the statute itself, we must read words and phrases in context and construe them in accordance with rules of grammar and common usage. [I]f such intent is clearly expressed therein, the statute may not be restricted, constricted, qualified, narrowed, enlarged or abridged (citing State ex rel. McGraw v. Gorman, 17 Ohio St.3d147, 149 (1985)).  In other words, the court reasoned that “if the meaning is unambiguous and definite, then the statute is to be applied as written and needs no further interpretation (citing State ex rel. Herman v. Klopfleisch, 72 Ohio St.3d 581, 584 (1995)).

Based upon these well-established laws of construction, the court in Cammelleri held that the intent of the ordinance is plain from the grammar and language used in West Jefferson Codified Ordinances 351.16(a), and accordingly, agreed with Ms. Cammelleri’s arguments.  As elaborated on by the court, “According to ordinary grammar rules, items in a series are normally separated by comma. However, no such comma exists…If the village desires a different reading, it should amend the ordinance and insert a comma between the phrase "motor vehicle" and the word "camper." As written, however, legislative intent is clear from looking at the language used in the ordinance itself.”

What is the moral of this story? Whether you are drafting commercial agreements, or statutory law, dot your i’s, cross your t’s, and don’t forget your commas. Grammar counts!

CLE Update: Upcoming CLE Seminars in Ohio

Continuing Education

As we head into the last few months of 2015, many of us in the State of Ohio have to complete by year end our continuing education requirements for our license. Below are some of the real estate related CLEs scheduled between now and year end.

Construction Law — 9/17 in Cleveland; 6.00 CLE hours

Title to Real Estate in Ohio video replay — 10/23, 12/7 in Fairfield; 6.00 CLE hours

Residential Real Estate Transactions and video replay — 11/6 in Lisbon, 11/18 in Columbus, Cleveland, Fairfield and Perrysburg, 12/10 in Celine and Gallipolis, and 12/14 in Cleveland, Columbus, Akron and Perrysburg; 6.00 CLE hours

Oil and Gas Update — 11/20 in Columbus, Cleveland, Akron and Wooster; 6.00 CLE hours

Real Property Institute — 12/10 in Columbus and Cleveland; 6.00 CLE hours

Commercial & Residential Landlord-Tenant Law — 9/25 in Cleveland and 10/23 in Dayton; 6.00 CLE hours

Retail, Office and Restaurant Leases: Key Provisions and Warranties — 9/1 in Cincinnati and 9/16 in Cleveland; 6.00 CLE hours

BOOT CAMP: Foreclosure and Loan Workout Procedures — 9/2 in Independence and 9/16 in Worthington; 6.00 CLE hours

Land Use Law: Current Issues in Subdivision, Annexation and Zoning — 10/1 in Cincinnati; 6.00 CLE hours

Top Title Defects – Cured — 11/2 in Dayton and 11/3 in Cincinnati; 6.00 CLE hours

Title Law from Start to Finish — 12/3 in Independence; 6.00 CLE hours

Practical Guide to Zoning and Land Use Law — 12/14 in Worthington; 6.00 CLE hours

Prefer to obtain some of your CLE hours online? Try…

Finally, below are links to the continuing education pages for some of the bar associations in Ohio: