In Norpac Realty Co. v. Schackne (1923) 107 Ohio St. 425, 1 Ohio Law Abs. 371, 140 N.E. 480, 21 Ohio L. Rep. 37, the Ohio Supreme Court considered a case in which a realty company purchased rental property, by means of a land installment contract, from Schackne for a total price of $ 50,000. Pursuant to the terms of the contract, the buyer provided a $ 12,500 first installment cash payment and agreed to make payments to the seller totaling $ 25,000 over the next three years. Id. at 425. For the remaining balance, the realty company assumed the $ 25,000 note and mortgage owed by Schackne on the property. Id. at 425-426. The buyer defaulted on the first payment of the $ 2,500. Id. at 426. Pursuant to the sales contract, upon default by the buyer, Schackne not only regained possession of the property but could also retain the $ 12,500 first installment payment "as stipulated damages" for nonpayment of the sales contract. Id. at 426-427. Schackne brought an action to regain possession of the property and asserted his right to retain the $ 12,500 cash installment. Id. The central issue in that case was whether stipulated damages in a contract for the sale of lands are a penalty or liquidated damages Id. at 427. Because (1) the buyer admitted the depreciation in the property's market value and (2) the rent for the property dropped from $ 500 to $ 250 per month during the buyer's year of possession, the Ohio Supreme Court found that, under the circumstances of that case, the $ 12,500 constituted liquidated damages. Id. at 428. The court further opined that even though the cash installment of $ 12,500 was large when considered in proportion to the purchase price of $ 50,000, "it was not so disproportionate, so extravagantly unreasonable, or so manifestly unjust as to require equitable interference with the contract agreed to." Id. at 430.