The Supreme Court of Ohio decided 47 cases today based on its prior ruling that a local board of education is unable to appeal the tax valuation of real property except for property it owns or leases.

In a unanimous entry, the Supreme Court affirmed decisions by courts of appeals denying local school district challenges to the tax valuations of properties within their boundaries.

Lawmakers enacted House Bill 126 in 2022, eliminating the ability of a board of education to appeal a county board of revision’s valuation of another owner’s property to the BTA. In a 6-1 decision in May, the Supreme Court found that the law did not simultaneously give a school board the ability to appeal such valuations to a court of common pleas through a general administrative appeal statute.

The Olentangy Local School District Board of Education had maintained that once lawmakers cut off a school district’s ability to appeal valuations to the Ohio Board of Tax Appeals (BTA), it opened the door to challenge taxation decisions in common pleas court. The Delaware County Common Pleas Court and the Fifth District Court of Appeals rejected Olentangy’s argument.

The Supreme Court found a board of revision’s property valuation decision falls outside the scope of decisions that may be appealed to a common pleas court.

The following cases had been held by the Court, pending its decision on the Olentangy Local appeal. Today’s entry decided the following cases:

  

• 2024-0797.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0798.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0799.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0800.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0801.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0802.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0803.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0804.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0806.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0807.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0810.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0811.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0812.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0813.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0816.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0817.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0818.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0819.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0820.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0821.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0822.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0824.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0825.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0826.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0827.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0829.  Westerville City School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0830.  Delaware City School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0831.  Delaware City School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0834.  Lancaster City School Dist. Bd. of Edn. v. Fairfield Cty. Bd. of Revision
• 2024-0835.  Lancaster City School Dist. Bd. of Edn. v. Fairfield Cty. Bd. of Revision
• 2024-0836.  Lancaster City School Dist. Bd. of Edn. v. Fairfield Cty. Bd. of Revision
• 2024-0837.  Lancaster City School Dist. Bd. of Edn. v. Fairfield Cty. Bd. of Revision
• 2024-0838.  Lancaster City School Dist. Bd. of Edn. v. Fairfield Cty. Bd. of Revision
• 2024-0839.  Lancaster City School Dist. Bd. of Edn. v. Fairfield Cty. Bd. of Revision
• 2024-0903.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-0954.  Cleveland Mun. School Dist. Bd. of Edn. v. Cuyahoga Cty. Bd. of Revision
• 2024-0996.  Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-1210.  Westerville City School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision
• 2024-1382.  Dublin City Schools Bd. of Edn. v. Union Cty. Bd. of Revision
• 2024-1383.  Marysville Exempted Village Schools Bd. of Edn. v. Union Cty. Bd. of Revision
• 2024-1384.  Dublin City Schools Bd. of Edn. v. Union Cty. Bd. of Revision
• 2024-1385.  Dublin City Schools Bd. of Edn. v. Union Cty. Bd. of Revision
• 2024-1386.  Dublin City Schools Bd. of Edn. v. Union Cty. Bd. of Revision
• 2024-1387.  Marysville Exempted Village Schools Bd. of Edn. v. Union Cty. Bd. of Revision
• 2024-1388.  Marysville Exempted Village Schools Bd. of Edn. v. Union Cty. Bd. of Revision
• 2024-1389.  Dublin City Schools Bd. of Edn. v. Union Cty. Bd. of Revision
• 2024-1702.  Marysville Exempted Village Schools Bd. of Edn. v. Union Cty. Bd. of Revision

In the same entry, the Court decided a 48th case. It affirmed the judgment of the Eighth District Court of Appeals in Bedford City Schools Bd.of Edn. V. Cuyahoga Cty. Bd. of Revision, based on both the 2026 Olentangy Local decision and its 2024 ruling that the Marysville Exempted Village School District could continue to challenge the property tax value of a private residential complex despite the 2022 change in state law.

In the 2024 case, the Court ruled that because of when the appeal was filed, the school board’s appeal could go forward even though the 2022 state law had limited the rights of local governments to appeal tax valuation decisions.

2024-0814 and 2024-0815. In re Cases Held for 2024-0814 and 2024-0815, Olentangy Local School Dist. Bd. of Edn. v. Delaware Cty. Bd. of Revision, Slip Opinion No. 2026-Ohio-2372.

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