Ohio court rules $350,000 farm sale proceeds go to heirs named in woman's will, not deed beneficiaries

An Ohio woman who agreed to sell her 62-acre farm to a land conservancy for $350,000 died just one day after the sale agreement took effect, leaving a legal dispute over who should receive the money. In a ruling issued on 5 October 2026, Ohio’s Eleventh District Court of Appeals held that the proceeds belong to the heirs named in Eleanor M. Hovanick’s will, rather than the beneficiaries listed on her transfer-on-death deed, according to the court’s opinion.The decision resolves a question of first impression in Ohio appellate courts: Whether a valid transfer-on-death designation survives when the property owner signs a binding sale contract before dying. The court concluded that it does not, because the sale agreement converted Hovanick’s interest in the land into a right to receive money, which then passed through her estate. Read more details about this case, as per the court report, here:The farm and the deedHovanick owned nearly 62 acres of real estate in Orwell, Ohio. In November 2010, she recorded a transfer-on-death designation affidavit naming Ann M. Zimmer, Carol Mohr, Michael Hovanick and Peggy Rodriguez as beneficiaries who would receive the land when she died.A transfer-on-death deed allows an owner to name people who will receive real estate after death without going through probate.