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Manufactured home's status as real property does not depend on surrender of motor vehicle title.(Recent Court Decisions)

Appraisal Journal

| March 22, 2009 | COPYRIGHT 2009 The Appraisal Institute. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan.  All inquiries regarding rights should be directed to the Gale Group. (Hide copyright information)Copyright

The Court of Appeals of Ohio ruled that a manufactured home was properly appraised as real property when it was affixed to the land, regardless of whether the motor vehicle title had been surrendered.

Robert Rickett is a certified real estate appraiser and the owner of the Country Manor Management and Appraisals Company. On July 20, 2001, one of his employees appraised a manufactured home located in a residential district, which she valued as real property. However, the homeowners did not surrender the motor vehicle certificate of title until July 24, 2001. That same day, Rickett signed the appraisal report as the supervisor appraiser, after determining that the home was bolted to the real estate and that the motor vehicle title had been surrendered.

In 2003, a citizen's complaint was filed with the state's real estate appraiser board alleging that the appraisal improperly valued the manufactured home as real property while it was still personal property; in 2006, the board sent notice of a hearing to Rickett charging him with a state law violation on those grounds. At the hearing, the board found that Rickett violated eight statutory standards by improperly appraising the home as real property.

He was ordered to complete 15 hours of education, assessed a civil penalty of $250, ...

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