Dublin City Schools Board of Education v. Franklin County Board of Revision
139 Ohio St. 3d 212
| Ohio | 2014Background
- 21 unfinished condominium units (out of 28) were valued by the county auditor as separate parcels for 2008, totaling $8,139,300; East Bank challenged these values, while Dublin City Schools sought to uphold them.
- BOR adopted Thomas Horner’s bulk-value appraisal, treating the 21 units as a single economic unit and valuing at $3,100,000.
- BTA initially reinstated the auditor’s $8,139,300 valuations, rejecting Horner’s bulk-appraisal approach as improper.
- This court previously reversed the BTA regarding bulk-appraisal but did not analyze the bulk-valuation approach’s legality; remanded for further consideration without addressing independent valuation.
- Dublin City Schools moved for reconsideration on three grounds, including remand for an independent BTA valuation; the majority granted reconsideration on two points but remanded for independent valuation.
- Court now remands to the BTA for an independent determination of value for the 21 units, disallowing Horner’s bulk-value approach and rejecting reinstate-to-auditor without independent analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether bulk-value appraisal was legally permissible | East Bank | Dublin City Schools | Bulk appraisal improper; violates R.C. 5311.11 and law; not the true value. |
| Whether the BTA should independently determine value rather than revert to auditor | East Bank | School board failed to prove alternative value; bulk-appraisal rejected | BTA must conduct independent valuation on remand. |
| Burden-shifting on appeal from BOR to BTA | East Bank | Board of Education bears burden if BOR adopted value | Burden shifted to School Board; evidence insufficient to sustain auditor’s value without independent BTA valuation. |
Key Cases Cited
- Bedford Bd. of Edn. v. Cuyahoga Cty. Bd. of Revision, 115 Ohio St.3d 449 (2007-Ohio-5237) (remand for independent valuation when record supports but BTA reinstatement improperly relies on auditor)
- Columbus City School Dist. Bd. of Edn. v. Franklin Cty. Bd. of Revision, 90 Ohio St.3d 564 (2001) (reaffirms burden-shifting and need for probative evidence on appeal to BTA)
- Vandalia-Butler City Schools Bd. of Edn. v. Montgomery Cty. Bd. of Revision, 130 Ohio St.3d 291 (2011-Ohio-5078) (independent valuation where sufficient evidence exists; BTA may order more evidence)
- Colonial Village, Ltd. v. Washington Cty. Bd. of Revision, 114 Ohio St.3d 493 (2007-Ohio-4641) (remand for independent valuation when BTA does not adequately determine value)
- Pingue v. Franklin Cty. Bd. of Revision, 87 Ohio St.3d 62 (1999) (bulky bulk-sale appraisal vs. allocated sale price; distinguishes sale evidence from appraisal)