Leonard v. Georgesville Ctr., L.L.C., 2013 Ohio 5713

Franklin County Treasurer sued to foreclose tax-delinquent property at 411 Georgesville Road; Oak Hill Banks (later WesBanco) was named for a mortgage interest.
WesBanco asserted successor status and mortgage/assignments of rent; trial court granted WesBanco summary judgment and entered a foreclosure decree in March 2012 (no appeal from that decree).
The court appointed a receiver following a hearing; appointment order entered February 14, 2013 (not appealed).
On April 24, 2013 the trial court approved the receiver's motions to retain a real estate broker and to retain counsel and approved the valuation used to create a listing price.
Appellants (Georgesville Center, LLC and Ashraf Ettayem) appealed the April 24 order; appellees moved to dismiss the appeal for lack of a final appealable order.
The court dismissed the appeal for lack of jurisdiction, concluding the April 24 order was not a final appealable order and denied sanctions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the April 24, 2013 order is a final appealable order	Order is not final; appeal should be dismissed (Leonard/WesBanco)	Order affects a substantial right because it approves valuation/listing price and thus is appealable (Georgesville/Ettayem)	Order is not final or appealable; appellate court lacks jurisdiction and appeal dismissed

Hubbell v. Xenia, 115 Ohio St.3d 77 (Ohio 2007) (appellate jurisdiction limited to final appealable orders)
Chef Italiano Corp. v. Kent State Univ., 44 Ohio St.3d 86 (Ohio 1989) (defining "substantial right" for final-order analysis)
Bell v. Mt. Sinai Med. Ctr., 67 Ohio St.3d 60 (Ohio 1993) (order affects substantial right if immediate appeal is necessary to avoid foreclosure of appropriate relief)
Circelli v. Keenan Constr., 165 Ohio App.3d 494 (Ohio Ct. App.) (an interim receivership order setting values does not necessarily create a final appealable order)