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Fonzi v. Brown Fonzi v. Miller, Ohio Supreme Court court found that surface owners did not exercise due diligence because they failed to search public records of Washington County, Pennsylvania. Resulting in surface owners’ attempts fell short compared to attempts made in Gerrity.
On March 24, 2022, the Supreme Court of Ohio issued its decision in Fonzi v. Brown and Fonzi v. Miller, Slip Opinion No. 2022-Ohio-901, discussing the level of due diligence required of.