State ex rel. Village of Chagrin Falls v. Geauga County Board of Commissioners

Summary

The Ohio Supreme Court held that the village had a plain and adequate remedy through an R.C. Chapter 2506 administrative appeal from the county commissioners’ denial of its annexation petition. The court concluded that the common pleas court could remand the matter for further proceedings and could consider additional evidence under the applicable statute. The court also held that the village waived constitutional claims not raised below and had not established judicial bias in the record.

Holdings

1. The village had a plain and adequate remedy in the ordinary course of law through its pending R.C. Chapter 2506 administrative appeal, so mandamus was unavailable.
2. A common pleas court hearing an R.C. Chapter 2506 administrative appeal may reverse an administrative decision and remand the matter to the administrative body for further proceedings, including a new hearing.
3. The common pleas court may consider additional evidence when one of the circumstances specified in R.C. 2506.03(A)(1) through (5) applies.
4. The village waived its constitutional claims by failing to raise them in the court of appeals, although it could raise those claims in its administrative appeal.
5. The Supreme Court of Ohio would not decide the bias claim because the record contained no evidence supporting it, and a judge is not automatically disqualified merely because the judge previously sponsored or voted on legislation later reviewed in a judicial capacity.

Questions Presented

1. Whether the village's R.C. Chapter 2506 administrative appeal was a plain and adequate remedy that precluded extraordinary relief in mandamus.
2. Whether a common pleas court hearing an R.C. Chapter 2506 appeal may remand an administrative decision for further proceedings, including a new hearing.
3. Whether the common pleas court may consider additional evidence under R.C. 2506.03.
4. Whether the village preserved constitutional claims concerning its annexation rights and the alleged suspension of former R.C. 709.031(A).
5. Whether the village established a basis for disqualification or bias of the court of appeals judge.

Disposition

affirmed