Gaston v. Medina County Board of Revision
133 Ohio St. 3d 18
| Ohio | 2012Background
- Medina County conducted a sexennial reappraisal for 2007, increasing Gaston's home value by 20% to 369,780 from 307,600.
- Gaston sought a true-value reduction to around the 2003 sale price of 329,915, arguing no changes or upgrades to the property.
- Gaston did not attend the Board of Revision (BOR) hearing; notice was mailed to his address by certified mail.
- At BOR, the auditor presented a comparable-sale study; the BOR retained the increased value.
- Gaston appealed to the BTA, presenting testimony and exhibits; the BTA excluded Gaston’s testimony and two exhibits under R.C. 5715.19(G) and adopted BOR’s valuation.
- The court ultimately affirmed the BTA, holding the evidence supported the county’s valuation and that service and evidentiary rulings were proper.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Gaston properly show improper service of the BOR notice? | Gaston did not receive proper notice; service invalidates BOR jurisdiction. | Certified mailing to Gaston's address with receipt constitutes valid service; presumption of proper service applies. | BOR service valid; Gaston failed to rebut presumption. |
| Whether the BTA abused discretion by excluding Gaston's evidence under R.C. 5715.19(G)? | Gaston’s exclusion prevented full consideration of evidence supporting a lower value. | BTA properly exercised discretion; Gaston failed to show good cause for failure to provide evidence earlier. | No abuse of discretion; evidence exclusion affirmed. |
| Did Gaston prove a value different from the county's true value? | Using the 2003 sale or other figures shows a lower true value. | No affirmative evidence supporting a different value; the county's comparable-sale study supports the value. | Gaston failed to prove a different, credible value. |
| Was the 2007 20% increase unreasonable under the reappraisal framework? | A 20% jump is excessively large and not explained by market data. | Increase may reflect correction of prior undervaluation and aligns with nearby comparisons; reappraisal duty supports it. | Not unreasonable; consistent with reappraisal duties and comparables. |
| Did the comparable-sale study properly influence the valuation? | The study should drive the valuation rather than be ignored by the BTA. | Even without weighting the study, its results align with the county's valuation and no error occurred. | BTA not required to accord weight to the study; valuation upheld. |
Key Cases Cited
- Gaston v. Medina Cty. Bd. of Revision, 133 Ohio St.3d 18 (Ohio 2012) (primary decision analyzed here)
- Knickerbocker Props., Inc. v. Del. Cty. Bd. of Revision, 119 Ohio St.3d 233 (2008) (BOR jurisdiction requires proper service)
- Cincinnati Sch. Dist. Bd. of Edn. v. Hamilton Cty. Bd. of Revision, 87 Ohio St.3d 363 (2000) (notice requirements and jurisdiction)
- Skuratowicz v. Tracy, 76 Ohio St.3d 103 (1996) (service by certified mail presumption of validity)
- Castellano v. Kosydar, 42 Ohio St.2d 107 (1974) (certified-mail service and receipt; rebuttal burden)
- New Co-Operative Co. v. Liquor Control Comm., 2002-Ohio-2244 (2002) (service presumptions and rebuttal standards)
- Tripodi v. Liquor Control Comm., 21 Ohio App.2d 110 (1970) (service and receipt considerations)
- Holmes v. Union Gospel Press, 64 Ohio St.2d 187 (1980) (administrative service validity context)
- Toledo v. Levin, 117 Ohio St.3d 373 (2008) (presumption of timely delivery in mail service)
- Dudukovich v. Lorain Metro. Hous. Auth., 58 Ohio St.2d 202 (1979) (mails and receipt timelines)
- State ex rel. Shafer v. Ohio Turnpike Comm., 159 Ohio St. 590 (1953) (official action presumed regular)
- Gahanna-Jefferson Local Sch. Dist. Bd. of Edn. v. Zaino, 93 Ohio St.3d 231 (2001) (standard for reviewing BTA valuation)
- AERC Saw Mill Village, Inc. v. Franklin Cty. Bd. of Revision, 127 Ohio St.3d 44 (2010) (auditor duties to reappraise; statutory framework)