Columbus City Schools Bd. of Edn. v. Franklin Cty. Bd. of Revision (Slip Opinion), 152 Ohio St. 3d 134

SD REI (a limited-liability company) purchased a rental residence in Feb 2010 for $26,000; HUD settlement statement lists Alonso Cruz signing as a “member.”
SD REI filed a complaint in Jan 2011 seeking to reduce the auditor’s 2010 valuation from $90,400 to $26,000; signature on the complaint was illegible and not identified in the filing.
At the BOR hearing SD REI did not appear; Cruz faxed documents to the BOR and labeled himself “manager” on the fax cover sheet.
The BOR reduced the 2010 valuation to $26,000 but retained higher values for 2011–2013; the BTA later adopted the $26,000 value for 2010–2013.
BOE challenged the BTA’s ruling on appeal, arguing the complaint was jurisdictionally defective because it was not signed by an officer, salaried employee, partner, or member as required by R.C. 5715.19(A)(1).
During BTA proceedings SD REI failed to identify who signed the complaint or to comply with discovery; the BOE moved for dismissal for lack of jurisdiction but the BTA denied the motion; the Supreme Court reversed and remanded for dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the BOR had jurisdiction under R.C. 5715.19(A)(1) because the complaint was signed by an authorized individual	BOE: The complaint was signed by someone without the statutory authority (signature illegible; no proof of officer/employee/partner/member status), so BOR lacked jurisdiction and complaint must be dismissed	SD REI/BTA: Circumstantial documents (settlement statement, contract, fax) show Cruz was a member/manager; BTA inferred authorization and declined to dismiss	Supreme Court: Held SD REI failed to meet its burden to prove the signer was authorized; complaint was jurisdictionally defective and must be dismissed

Toledo Pub. Schools Bd. of Edn. v. Lucas Cty. Bd. of Revision, 124 Ohio St.3d 490, 2010-Ohio-253, 924 N.E.2d 345 (explains de novo review of BOR jurisdictional sufficiency)
Crown Communications v. Testa, 136 Ohio St.3d 209, 2013-Ohio-3126, 992 N.E.2d 1135 (confirms plenary review authority over tax-tribunal jurisdiction)
Richman Properties, L.L.C. v. Medina Cty. Bd. of Revision, 139 Ohio St.3d 549, 2014-Ohio-2439, 13 N.E.3d 1126 (member of an LLC has statutory authority to file on behalf of the company)
Worthington City Schools Bd. of Edn. v. Franklin Cty. Bd. of Revision, 124 Ohio St.3d 27, 2009-Ohio-5932, 918 N.E.2d 972 (full compliance with R.C. 5715.19 is prerequisite for BOR jurisdiction)
Marysville Exempted Village Local School Dist. Bd. of Edn. v. Union Cty. Bd. of Revision, 136 Ohio St.3d 146, 2013-Ohio-3077, 991 N.E.2d 1134 (party asserting jurisdiction bears burden to prove it)
Columbus City School Dist. Bd. of Edn. v. Franklin Cty. Bd. of Revision, 134 Ohio St.3d 529, 2012-Ohio-5680, 983 N.E.2d 1285 (statute specifies narrow class of persons authorized to file on behalf of an owner)
Ohio Natl. Life Ins. Co. v. United States, 922 F.2d 320 (when jurisdictional facts are challenged, the claimant must demonstrate jurisdiction)