Background
Candlewood Custom Homes entered into a contract with Brian and Melissa Saunders for construction of a home, with an estimated cost of $346,500 and a $55,000 management fee. The relationship deteriorated in 2020, and Candlewood stopped work. Both sides filed competing claims: Candlewood sought damages for breach of contract, unjust enrichment, and mechanic’s lien foreclosure; the Saunders counterclaimed for breach of contract, unjust enrichment, workmanship deficiencies, and slander of title.
After a bench trial before a magistrate, both parties’ breach of contract claims were denied, the mechanic’s lien was declared invalid, and Candlewood was awarded $20,544 in unjust enrichment. The Saunders then moved for a new trial, arguing the magistrate should have disqualified herself because she made a $100 contribution to the campaign of appellants’ counsel’s opponent in the 2024 Republican primary for an Ohio House seat.
The Court’s Holding
The Fourth District affirmed the trial court’s denial of the new trial motion and the unjust enrichment award. On the disqualification question under Jud.Cond.R. 2.11(A)(1), the court applied the objective test for appearance of impropriety: whether a “reasonable and objective observer would harbor serious doubts about the judge’s impartiality.” The court found that a $100 campaign contribution to the political opponent of a party’s attorney does not create such doubts, distinguishing cases involving direct financial interests or ex parte communications.
The court also affirmed the denial of both parties’ contract claims and the unjust enrichment award, noting that without a transcript, the trial court properly presumed regularity of the proceedings. Candlewood’s cross-appeal challenging a $5,000 reduction and the denial of prejudgment interest was also rejected.
Key Takeaways
- A magistrate’s $100 campaign contribution to the political opponent of a party’s attorney does not, standing alone, require disqualification under Jud.Cond.R. 2.11(A)(1) or create an appearance of impropriety that warrants a new trial.
- Parties who fail to provide a transcript of proceedings before a magistrate must accept the presumption of regularity when challenging the magistrate’s factual findings on appeal.
- Unjust enrichment can provide recovery even when both parties’ breach of contract claims fail, as long as the elements of unjust enrichment are independently established.
Why It Matters
This decision provides welcome clarity on the intersection of judicial ethics and political activity. As magistrates and judges increasingly participate in the political process, practitioners may face similar disqualification questions. The court’s bright-line approach — treating small-dollar political contributions as insufficient to trigger recusal — gives both bench and bar a practical standard. Construction and real estate attorneys should also note the unjust enrichment holding: even where a construction contract exists, equitable relief remains available when the contract claims fail on both sides.