Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision

Summary

The Supreme Court of Ohio held that R.C. 2506.01(C) excludes county board of revision property-valuation decisions from appeals to a court of common pleas because such decisions are appealable to the Board of Tax Appeals under R.C. 5717.01. The court further concluded that direct appeals under R.C. 5717.05 are available only to the person in whose name the property is listed or sought to be listed for taxation. The court affirmed the Fifth District Court of Appeals' judgment upholding dismissal of Olentangy Local School District Board of Education's appeals.

Holdings

1. R.C. 2506.01(C) excludes a board of revision's property-valuation decisions from the class of final orders, adjudications, or decisions appealable to a common pleas court under R.C. 2506.01(A), because R.C. 5717.01 provides an appeal to the higher administrative authority of the Board of Tax Appeals and provides a right to a hearing.

Questions Presented

1. Whether R.C. 2506.01(A) provides a board of education with an independent right to appeal a board of revision's property-valuation decision to a court of common pleas.
2. Whether R.C. 2506.01(C)'s exclusion for decisions appealable to a higher administrative authority applies when the board of education itself cannot appeal the particular valuation decision to the Board of Tax Appeals after the 2022 amendment to R.C. 5717.01.
3. Whether the statutory scheme permits Olentangy to appeal the Board of Revision's property-valuation decisions to the common pleas court.

Disposition

affirmed