Salone v. Stovall

Citations

• 2025 Ohio 968

Syllabus

Declaratory judgment; quiet title; deed; fraudulent transfer; motion for summary judgment; voluntary satisfaction; judgment; stay; moot. Appeal dismissed as moot. Plaintiff claimed that defendants defrauded her out of her home and recorded a fraudulent deed. The trial court granted plaintiff's motion for summary judgment, voided the fraudulent deed, and entered declaratory judgment ordering that the subject property is quieted and all right, title and interest is vested in plaintiff. Plaintiff recorded a copy of the trial court's judgment entry with the Cuyahoga County Fiscal Office. The next day, defendants filed the instant appeal and sought a stay of the judgment with the trial court five days later. The trial court denied the stay as moot, finding that plaintiff has already executed the judgment. It is a well-established principle of law that a satisfaction of judgment renders an appeal from that judgment moot. Here, defendants failed to obtain a stay of the trial court's judgment nullifying a quitclaim deed to the subject property prior to plaintiff quieting title against the defendants. Therefore, the appeal is moot.