Goering v. Schille, 2012 Ohio 3330

Plaintiff Goering pursued foreclosure for delinquent real estate taxes on McCarren's property; sale to ETC occurred at sheriff's sale and was confirmed.
The magistrate's decree of confirmation was adopted by the trial court, and McCarren moved to vacate the confirmation; the magistrate denied this motion.
The trial court vacated the decree of confirmation in July 2011 but scheduled a later hearing to decide whether to vacate the confirmation.
In August 2011, the court sustained McCarren's objections, vacated the confirmation, and conditioned reinstatement on McCarren paying delinquent taxes and costs, with a potential reinstatement if redeemed.
In September 2011, the court held the July and August entries were final and appealable; ETC appealed but the court later dismissed for lack of jurisdiction, finding none of the entries final.
The appellate court dismissed the appeals for lack of final, appealable orders under R.C. 2505.02 and related precedents.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Were the July entry final, appealable orders?	ETC contends July entry vacated the decree and thus was final.	McCarren contends the July entry was interlocutory and not final.	Not final; July entry interlocutory and non-appealable.
Were the August entry final, appealable orders?	ETC argues August entry left unresolved contingencies, not final.	McCarren contends contingencies still rendered it non-final.	Not final; August entry created contingencies and was not appealable.

Chef Italiano Corp. v. Kent State Univ., 44 Ohio St.3d 86 (1989) (finality of orders under Civ.R. 54(B) analysis and 2505.02)
General Acc. Ins. Co. v. Ins. Co. of N. America, 44 Ohio St.3d 17 (1989) (finality and jurisdiction for appeals)
Sky Bank v. Mamone, 182 Ohio App.3d 323 (2009) (final, appealable order requirements under 2505.02)
State v. Threatt, 108 Ohio St.3d 277 (2006) (judgment leaving issues unresolved not final)