Nelnet, Inc. v. Rauch, 2019 Ohio 561

Emily K. Rauch purchased the subject parcel in 1999; she died intestate in 2008, survived by her husband and two adult daughters.
Nelnet purchased two delinquent-tax certificates on the parcel in 2009 and 2010 and filed a foreclosure complaint in December 2010 naming Rauch and unknown heirs/spouse.
Nelnet's pleadings and service attempts used the address "1296 Oak Hill Road, Columbus, Ohio 43220;" mailed attempts were returned as undeliverable; Nelnet obtained service by publication and a default foreclosure judgment in 2011.
The property was sold at sheriff's sale in 2012 and subsequently conveyed to later purchasers; deeds and later instruments identified the property as being in Blacklick, Ohio (43004).
Appellants (Rauch heirs/estate) moved in 2017 to declare the foreclosure judgment void for lack of personal jurisdiction, arguing Nelnet never served the correct Blacklick address; the trial court granted the motion in June 2018 and voided the foreclosure judgment and subsequent orders.
The trial court also made an ancillary statement that current owners appeared to be good-faith purchasers; appellants appealed, challenging that portion of the order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court had personal jurisdiction over appellants (proper service)	Nelnet implicitly contends service by publication and prior efforts were adequate to support the foreclosure judgment	Appellants argue Nelnet never served them at the correct Blacklick address; therefore the court lacked personal jurisdiction and the foreclosure is void	Court affirmed: trial court correctly found lack of personal jurisdiction and voided the foreclosure judgment (appellants prevailed on this point)
Whether the trial court erred by commenting on the status of subsequent purchasers and whether that comment was appealable	Nelnet (implicitly) did not contest the characterization of subsequent purchasers or the trial court's ancillary comments	Appellants argued the court improperly declared nonparties to be good-faith purchasers and that the comment clouded title / impeded probate sale	Court held the statement about current owners was dictum or an advisory opinion, unnecessary to the ruling on service, and thus not subject to appeal; appellants’ assignments of error were overruled

State ex rel. Coble v. Lucas Cty. Bd. of Elections, 130 Ohio St.3d 132 (2011) (statement unnecessary to holding constitutes dicta)
State ex rel. Draper v. Wilder, 145 Ohio St. 447 (1945) (distinguishing advisory opinions as nonbinding)
Walther v. Central Trust Co., N.A., 70 Ohio App.3d 26 (1990) (appellate court discussing limits on appealing dictum)