Licking Hts. Local Schools Bd. of Edn. v. Franklin Cty. Bd. of Revision (Slip Opinion), 2018 Ohio 3255

CK at Broad filed an R.C. 5715.19(A) complaint (an "A complaint") in March 2012 challenging only the land valuation for tax year 2011; BOE filed a complaint under R.C. 5715.19(B) (a "B complaint") in May 2012 seeking an increased total valuation.
CK at Broad later discovered its acreage assumption was mistaken (a parcel split in Nov. 2011) and voluntarily dismissed its A complaint in 2014.
The Franklin County Board of Revision (BOR) proceeded on the BOE’s B complaint, holding hearings and adopting certain land values while retaining auditor improvement values for some years.
The BOE appealed to the Board of Tax Appeals (BTA); the BTA concluded it had jurisdiction and held both land and improvement values were at issue, adopting the BOE’s appraiser values for 2011–2013.
CK at Broad appealed to the Ohio Supreme Court, raising two jurisdictional challenges: (1) whether the owner’s voluntary dismissal of the A complaint divested the BOR/BTA of jurisdiction over the BOE’s B complaint, and (2) whether the BOR/BTA were limited to addressing only land value because the A complaint had contested land only.

Issue	Plaintiff's Argument (CK at Broad)	Defendant's Argument (BOE)	Held
Whether voluntary dismissal of an A complaint after a B complaint was filed strips BOR/BTA of jurisdiction over the B complaint	Dismissal of the A complaint eliminated the jurisdictional basis for the B complaint; C.I.A. requires dismissal of the B complaint when the A complaint is not valid or withdrawn	C.I.A. concerns jurisdictionally defective A complaints; when a B complaint is validly filed, later voluntary dismissal of the A complaint does not retroactively defeat jurisdiction — jurisdiction is assessed at time of filing	The court held the time-of-filing rule applies: because the BOE’s B complaint was valid when filed, the later voluntary dismissal of the A complaint did not defeat BOR/BTA jurisdiction over the B complaint
Whether the BOR/BTA were limited to deciding land value because the A complaint contested only land	The BOR/BTA could only address what the owner put at issue (land) — BOE’s B complaint cannot expand the scope beyond the original A complaint	R.C. 5715.19 and precedent permit a complaint to place total parcel value (land and improvements) at issue; boards may independently determine total value regardless of how the original complainant framed its claim	The court held BOR/BTA jurisdiction under the BOE’s B complaint was not limited to land; both land and improvement values could be considered and revalued

C.I.A. Properties v. Cuyahoga Cty. Aud., 89 Ohio St.3d 363 (2000) (held a B complaint does not create independent jurisdiction where the A complaint was jurisdictionally defective)
Soyko Kulchystsky, L.L.C. v. Cuyahoga Cty. Bd. of Revision, 141 Ohio St.3d 43 (2014) (jurisdiction and statute-eligibility questions are assessed as of the time a complaint is filed)
Blatt v. Hamilton Cty. Bd. of Revision, 123 Ohio St.3d 428 (2009) (R.C. 5715.19(A) places total property value—land and improvements—at issue)
Huber Hts. City Schools Bd. of Edn. v. Montgomery Cty. Bd. of Revision, 152 Ohio St.3d 182 (2017) (BTA performs independent valuation and is not bound by parties’ proposed values)