Justia Ohio Supreme Court Opinion Summaries

In 2010, the Talawanda City School District Board of Education (BOE) filed its application to exempt property located within the district. The tax commissioner granted an exemption for all of the property except for a parcel being farmed pursuant to lease, concluding that the pecuniary benefit realized by the farmer disqualified the land from exemption because that portion was not used for school purposes. The Board of Tax Appeals affirmed. the Supreme Court reversed, holding (1) following its amendment in 2010, Ohio Rev. Code 3313.44 does not contain a restriction requiring that the property owned by the BOE be used exclusively for school purposes; and (2) the entire property described in the BOE’s application shall be exempt for the year at issue. View "Talawanda City Sch. Dist. Bd. of Educ. v. Testa" on Justia Law

Appellee challenged the auditor’s valuation of a parcel of residential real estate for tax year 2012. The Columbus City Schools Board of Education (school board) sought retention of the auditor’s valuation. The Franklin County Board of Revision dismissed the complaint. Appellee appealed to the Board of Tax Appeals (BTA) from the dismissal order. On the notice of appeal, Appellee marked “yes” in response to a question asking whether the case should be referred to the small-claims docket. Accordingly, the case was placed on the small-claims docket. The school board filed a motion to return the case to the regular docket. The BTA denied the motion. The Supreme Court exercised its jurisdiction to review the interim order and affirmed the BTA’s denial of the school board’s motion, holding that the BTA did not err in denying the school board’s motion to have the case returned to the BTA’s regular docket. Remanded. View "Megaland GP, LLC v. Franklin County Bd. of Revision" on Justia Law

In 2010, Steak ’n Shake filed a complaint seeking a reduction for tax year 2009 from the auditor’s valuation of a Steak ’n Shake restaurant. The Warren County Board of Revision retained the auditor’s original valuation for the property. Stake ’n Shake appealed to the Board of Tax Appeals (BTA). At the BTA hearing, the property owner presented an appraisal report and testimony from a longtime state-certified appraiser, while the county presented an appraisal prepared by an employee of the county’s valuation consultant. The BTA adopted the county’s valuation. The Supreme Court reversed, holding (1) Steak ’n Shake’s objections to the competency and lack of independence of the county’s appraiser are rejected; but (2) the BTA erred in its acceptance of the county appraiser’s reliance on encumbered comparable properties in determining the value of the subject property, which is occupied by its owner. Remanded. View "Steak 'n Shake, Inc. v. Warren County Bd. of Revision" on Justia Law

In 2011, Donald Beck filed complaints against the auditor’s tax-year-2010 valuations of three two-family residential rental properties in Columbus. The Franklin County Board of Revision approved a reduction in the auditor’s original valuation based upon an unspecific sales-comparison and income approach. The Board of Tax Appeals (BTA) affirmed the reduction. The Columbus City Schools Board of Education (BOE) appealed, arguing that the BTA improperly affirmed the reduced valuation when the evidence for the reduction was not in the record. The Supreme Court affirmed the decision of the BTA, holding that the BOE waived its claim of error because it presented neither argument nor evidence before the BTA. View "Columbus City Schs. Bd. of Educ. v. Franklin County Bd. of Revision" on Justia Law

The parties in this case disputed who was the legal owner or holder of certain mineral rights. The United States District Court for the Southern District of Ohio, Eastern Division concluded that the interpretation of Ohio’s Dormant Mineral Act in the context of an oil and gas lease was determinative of the case and certified certain questions to the Supreme Court for answers. The questions were as follows: (1) whether a recorded lease of a severed subsurface mineral estate is a title transaction under the Act, and (2) whether the expiration of a recorded lease and the reversion of the rights granted under that lease is a title transaction that restarts the twenty-year forfeiture clock under the Act at the time of the reversion. The Supreme Court answered (1) a recorded lease of severed oil and gas rights is a title transaction under Ohio Rev. Code 5301.56(B)(3)(a) that constitutes a saving event to preclude the severed mineral rights from being deemed abandoned and reunited with the rights to the corresponding surface property; but (2) the unrecorded expiration of such a lease is not a title transaction that restarts the twenty-year clock under the Act. View "Chesapeake Exploration, LLC v. Buell" on Justia Law

The Franklin County auditor valued property owned by Sears, Roebuck & Company at $8,323,000 for the tax year 2005 and for tax years 2006 through 2010. Sears filed a complaint seeking a reduction of value. The Franklin County Board of Revision (BOR) rejected Sears’s claims for reduction. Sears appealed to the Board of Tax Appeals (BTA), where Sears presented an appraisal determine the value to be $6,300,000 for 2005 and $6,550,000 for 2008. The Columbus City Schools Board of Education presented data as rebuttal evidence. The BTA adopted the Sears appraisal valuations. The Supreme Court affirmed the BTA’s decision, holding (1) the BTA’s decision was not unreasonably or unlawful on account of alleged formal inadequacies; and (2) the BTA was justified in concluding that the appraiser’s opinion was supported by a viable theory of property value. View "Sears, Roebuck & Co. v. Franklin Cty. Bd. of Revision" on Justia Law

Platinum Lodging, LLC, the former owner of the property at issue in this appeal, was a party throughout proceedings challenging a real property valuation for the tax year 2008. The Franklin County Board of Revision (BOR) reduced the valuation. Platinum Lodging and the current property owners appealed to the common pleas court. The common pleas court remanded the matter to the BOR. On remand, the BOR dismissed the complaint on the grounds that the complainant lacked standing. The Columbus City Schools Board of Education and Platinum Lodging appealed. The Board of Tax Appeals (BTA) dismissed the appeals on the grounds that, because the first appeal had been filed in the common pleas court, the BTA lacked jurisdiction to entertain an appeal from the BOR’s dismissal order on remand. The Supreme Court reversed the BTA’s order or dismissal as to Platinum Lodging, holding that Platinum Lodging acted properly in filing its notice of appeal at the BTA instead of in the common pleas court. Remanded to the BOR with instructions that it determine the value of the property in accordance with the earlier remand order issued by the common pleas court. View "Columbus City Schs. Bd. of Educ. v. Franklin County Bd. of Revision" on Justia Law

The Northeast Ohio Regional Sewer District (the “Sewer District”) filed an action seeking a declaratory judgment that it had the authority to implement a regional stormwater-management program and to impose fees to be charged to landowners within the Sewer District. The trial court declared that the Sewer District had authority under Ohio Rev. Code 6119 and its charter to enact a regional stormwater-management program. The court of appeals reversed. The Supreme Court reversed, holding that the Sewer District has authority to implement a regional stormwater-management program and to charge fees for that program. View "Northeast Ohio Reg’l Sewer Dist. v. Bath Twp." on Justia Law

At issue in this case was the tax year 2008 valuation of an office-warehouse building in west Columbus. The Franklin County Board of Revision (BOR) reduced the value assigned to the property from the $2,750,000 found by the auditor to the $1,520,000 advocated in an appraisal submitted by the property owner. The Columbus City Schools Board of Education (BOE) appealed. The Board of Tax Appeals (BTA) affirmed. The Supreme Court affirmed the decision of the BTA, holding (1) alleged defects in the wording of the BTA’s decision do not establish it to be unreasonable or unlawful; (2) the BTA is not required to issue formal findings of fact and conclusions of law; (3) alleged errors in the appraisal furnish no basis for reversal; and (4) the BOE failed to satisfy its burden under the rule announced in Bedford Bd. of Educ. v. Cuyahoga County Bd. of Revision. View "Columbus City Sch. Bd. of Educ. v. Franklin Cty. Bd. of Revision" on Justia Law

In 2011, Appellant purchased a two-family dwelling from the United States Department of Housing and Urban Development for $5,000. The Cuyahoga County fiscal officer valued the property at $126,800 for tax year 2011. Appellant sought a reduction to $30,000. The County Board of Revision retained the fiscal officer’s valuation. The Board of Tax Appeals (BTA) affirmed. The Supreme Court reversed, holding that the BTA acted unreasonably when it found that the property’s 2011 sale price was not the best evidence of its tax year 2011 value. Remanded with instructions that the $5,000 sale price be used as the property’s value for tax year 2011. View "Schwartz v. Cuyahoga County Bd. of Revision" on Justia Law