The Ohio Supreme Court ruling landed on April 22, 2026. Most mobile home park owners still haven’t heard about it.

That gap — between what’s happening legally and what operators actually know — is exactly how exposure turns into liability.

Here’s what you need to know, and what you need to do about it.

What Changed in Ohio (And Why It Matters Everywhere Else)

On April 22, 2026, Ohio’s Supreme Court declared that submetering companies operating in mobile home communities are public utilities, subject to regulation by the state’s Public Utilities Commission.

The practical result: utility markups that were previously treated as straightforward operating income may now be subject to rate review. Tenant consumer protections — the kind that give residents legal standing to dispute billing — now apply to the full billing relationship. One of the largest submetering operators in the country was directly affected.

But here’s the thing: this isn’t an Ohio story. It’s the latest move in a regulatory chain reaction that’s been building for three years.

The Timeline You Need to Know

• January 2025: Minnesota banned Ratio Utility Billing Systems (RUBS) entirely for electricity. Water and gas billing came under strict state mandates. Administrative markups: prohibited.
• 2025: Arizona’s Attorney General issued consumer alerts warning that RUBS overbilling could constitute fraud. Class-action lawsuits are actively working through courts in Los Angeles.
• July 2027: Colorado’s HB 25-1090 bans RUBS for all new construction.
• Pending: California, Washington, and New York all have active or pending legislation. Federal advocacy groups are pushing manufactured housing billing protections at the national level.

RUBS — the practice of dividing a master utility bill among residents based on a formula (square footage, occupancy, etc.) rather than actual measured usage — has been a standard part of the mobile home park operator playbook for decades. In states that haven’t moved yet, operators often assume they’re safe. They aren’t. They’re lagging.

The Real Exposure Most Operators Miss

Most operators think about this as a “future problem.” Here’s why it isn’t:

Arizona’s AG office is actively sending warning letters right now. Minnesota operators who didn’t switch in time are sitting on billing refund claims from residents. The Ohio ruling is already being cited in other jurisdictions as precedent.

And the second misconception: “We switched to submeters, so we’re fine.” Not necessarily. If your submetering setup involves a third-party billing company that marks up utility costs, the Ohio ruling may apply to your operation — depending on how your state courts interpret it.

There’s a compounding factor here too. An AP investigation found that nearly 70% of mobile home parks running their own water systems violated safe drinking water rules in the last five years. Billing compliance and water quality compliance are two separate issues — but regulators don’t treat them separately when they’re looking at your operation.

The Path Forward

Step 1: Do a State-by-State Compliance Audit

Map every park in your portfolio against current law in its state. For each park, document: (a) what billing method is currently in use, (b) whether that method is explicitly permitted under current state law, and (c) when the law last changed. If you have more than a handful of parks, build a real system for this — not a mental note.

Step 2: Model the Submeter Conversion Economics Honestly

Individual submetering — billing residents based on actual measured usage — is the most legally defensible billing model in every state. The conversion costs $800–$2,500 per pad, which is real money. A 100-lot park can run you $80,000–$250,000 to convert.

But run the actual math before you decide to wait:

• Submetered parks typically see 20–40% reduction in total water usage as residents become accountable for their own consumption
• Individual meters detect leaks immediately — a single undetected leak can cost thousands per month
• Legal exposure from continued RUBS use is a liability that doesn’t show up cleanly on a P&L until it does

In our portfolio at Keel Team, submeter conversion has consistently turned ROI-positive within 18–24 months. The billing investment pays for itself.

Step 3: Automate Billing and Create an Audit Trail

Manual meter reading creates errors. Errors create disputes. Disputes create the AG investigations and class-action plaintiff pools that are actively building right now.

Platforms built specifically for manufactured housing communities — including Yardi’s manufactured housing manager module (launched December 2025), SimpleSubwater, and Synergy Utility Billing — automate meter reading, apply state-compliant billing formulas, and generate the documentation you’ll need if you’re ever challenged.

The operators who avoid liability in the next wave of state actions won’t be the ones doing something deliberately wrong. They’ll be the ones who can document that they weren’t.

What To Do This Week

1. Pull your billing setup for every park in your portfolio
2. Cross-reference it against the current legal status of your state (RUBS allowed? Submetering markup permitted? Any pending AG actions?)
3. If you’re running RUBS in a state with pending or recent restrictions, get an attorney on the phone this week — not next quarter
4. If you’re planning an acquisition, utility billing compliance should be on your due diligence checklist alongside water system inspections and title

The operators who treat this as a future problem are the ones who’ll be managing it as a crisis. The operators who act now will have a clean, auditable billing system and a legal position that’s hard to challenge.

At Keel Team, we’ve been working through this across our own portfolio. The process is manageable. The window to do it on your own timeline — rather than someone else’s enforcement timeline — is still open. But it won’t stay open forever.

If you’re evaluating a mobile home park acquisition and want a structured framework for utility billing due diligence, our Mobile Home Park Due Diligence Playbook covers utility audits, billing compliance, and infrastructure assessment in detail.

Andrew Keel is CEO of Keel Team Mobile Home Park Investments, a private equity firm focused on manufactured housing communities. Keel Team owns and operates 50+ mobile home parks across the Southeast and Midwest.