Adams v. Harris, 2024 Ohio 4640

This case involves Ohio landowners challenging the Tax Commissioner’s setting of a $1,000 per acre woodland clearing-cost deduction for property tax valuation under the Current Agricultural Use Valuation (CAUV) program for tax years 2015-2020.
The CAUV allows Ohio farmland, including woodlands, to be taxed based on agricultural value rather than fair market value, with a deduction for the cost of converting woodlands to cropland.
From 1983 to 2014, the deduction was $500/acre before the Commissioner raised it to $1,000 for 2015 and carried that number through subsequent years, despite evidence of higher actual clearing costs.
Landowners argued this resulted in overvaluation and higher taxes; the Board of Tax Appeals (BTA) upheld the Commissioner’s figure, finding no abuse of discretion.
The Supreme Court of Ohio took up the appeal, also addressing various cross-appeal issues about standing, multi-party appeals, and whether landowners were required to raise objections at Commissioner hearings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of $1,000 Clearing-Cost Rate	Rate is too low, unsupported by reliable evidence	Chosen rate within discretionary authority	$1,000 rate was arbitrary and unreasonable—reversed
Whether Tax Commissioner Followed CAUV Rule Requirements	Commissioner failed to use best/reliable data	Sought reliable data but found submissions unreliable	Commissioner failed required inquiry—remand to comply
Standing of Plaintiffs and Jurisdiction for Multi-Taxpayer Appeals	Plaintiffs had standing; multi-party appeals allowed	Only impacted taxpayers may appeal; statutes are singular	Court: singular includes plural, at least one taxpayer suffices
Necessity to Object at Commissioner Hearing	Not required by statute/rule	Failure to object at hearing bars later appeal	Not required—public hearings are nonadversarial

Adams v. Testa, 2017-Ohio-8853 (final determination in CAUV valuation is appealable to BTA)
Johnson v. McClain, 2021-Ohio-1664 (abuse-of-discretion standard applies for BTA review of Tax Commissioner’s CAUV determinations)
AAAA Ents., Inc. v. River Place Urban Redevelopment Corp., 50 Ohio St.3d 157 (defines arbitrary and unreasonable administrative decisions)
Dayton ex rel. Scandrick v. McGee, 67 Ohio St.2d 356 (clarifies arbitrary government action as lacking standards or guideposts)
State ex rel. Gilreath v. Cuyahoga Job & Family Servs., 2024-Ohio-103 ("shall" in a rule/statute is mandatory unless otherwise indicated)