Bedford City Schools Bd. of Edn. v. Cuyahoga Cty. Bd. of Revision

Citations

• 2024 Ohio 1894

Syllabus

Administrative appeal R.C. 5717.01 R.C. 5717.05 R.C. 2506.01 standing motion to dismiss Civ.R. 12(B)(6) valuation property school board. The appellant school board had no standing to appeal a valuation decision made by a county board of revision to the common pleas court when the board did not own or lease the property at issue. We rejected the argument that R.C. 2506.01 conferred standing to appeal. That is a general statute, which is silent as to who has standing to file an administrative appeal. Later-enacted statutes specifically covering these kinds of valuation appeals — R.C. 5717.01 and 5717.05 — clearly prohibit a school board from appealing adverse decisions to a common pleas court when the board is not the property owner or a lessee. Recent amendments to these statutes, which eliminated a school board's ability to appeal valuation decisions even to the board of tax appeals, further support the conclusion that the legislature's intent was to eliminate a school board's ability to appeal these decisions under most circumstances. The trial court correctly dismissed the school board's appeal, and therefore its judgment is affirmed.