The Eighth District Court of Appeals affirmed the Berea Municipal Court's holding that generic advertising was not sufficient to fulfill the landlord's duty to mitigate damages. During the slow rental months of December and January, a generic print ad for available space in the entire apartment complex was sufficient. Subsequently, the landlord should have made more efforts to rent out the particular unit in question. Oakwood Estates v. Crosby, 2005-Ohio-2457, May 15, 2005.
