Boler v. Rittman

2025 Ohio 5780
CourtOhio Court of Appeals
DecidedDecember 29, 2025
Docket25AP0010
StatusPublished

This text of 2025 Ohio 5780 (Boler v. Rittman) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Boler v. Rittman, 2025 Ohio 5780 (Ohio Ct. App. 2025).

Opinion

[Cite as Boler v. Rittman, 2025-Ohio-5780.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF WAYNE )

TARA BOLER, et al. C.A. No. 25AP0010

Appellants

v. APPEAL FROM JUDGMENT ENTERED IN THE CITY OF RITTMAN, OHIO COURT OF COMMON PLEAS COUNTY OF WAYNE, OHIO Appellee CASE No. 2023 CVC-H 000141

DECISION AND JOURNAL ENTRY

Dated: December 29, 2025

STEVENSON, Judge.

{¶1} Plaintiffs-Appellants Tara Boler and Trista Bise (the “Taxpayers”) appeal from the

judgment of the Wayne County Court of Common Pleas that granted summary judgment in favor

of Defendant-Appellee City of Rittman (the “City”) on the Taxpayers’ complaint for repayment

of wrongfully collected and unjustly retained municipal income taxes. For the reasons set forth

below, this Court affirms.

I.

{¶2} In 1977 the City’s voters approved a tax levy that authorized a 1.5% municipal

income tax rate for a period of 30 years, from January 1, 1977, to December 1, 2007. Following

approval of the levy, sections 191.02 and 191.03 of the Rittman Codified Ordinances authorized

the collection of the 1.5% rate. However, beginning in 2008, when the City was only permitted to

impose a 1.0% municipal income tax, it continued to impose and collect a municipal income tax 2

rate of 1.5% for each year until January 2023. According to the City, it discovered the error in

July 2022.

{¶3} In a letter to its taxpayers dated January 19, 2023, the City admitted its error and

refunded the over-collection from the year 2022. The City refused to refund the over-collection

from 2008-2021, characterizing the situation as an “unfortunate result” and citing “legal and

practical reasons” why it could not. On January 30, 2023, the City held a special City Council

meeting. Approximately 300 taxpayers attended the meeting and demanded refunds, but again,

the City refused to authorize refunds for the tax years 2008-2021. The City’s position was that the

tax money collected during those years had already been spent and was no longer in the City’s

possession, and the applicable one-year statute of limitations under R.C. 2723.01 had expired.

{¶4} In April 2023, Plaintiff-Appellant Boler filed a complaint against the City setting

forth claims for declaratory judgment under Rittman Codified Ordinance 191.16; violation of R.C.

718.12 (Refunds of Municipal Income Taxes); unjust enrichment; and money had and received.

The complaint was later amended to include Plaintiff-Appellant Bise. The Taxpayers sought

restitution of the sums wrongfully collected and retained. The City moved to dismiss the complaint

for lack of subject matter jurisdiction and failure to state a claim, or in the alternative for summary

judgment, arguing that the matter was governed by R.C. 2723.01 rather than R.C. Ch. 718 as

alleged in the complaint. The trial court denied the motion, reasoning that the Taxpayers had

properly sought recovery of the overpaid taxes under R.C. Ch. 718.

{¶5} After the trial court denied the City’s motion to dismiss, the City filed a writ of

prohibition action with the Ohio Supreme Court, alleging in its complaint that the trial court lacked

subject matter jurisdiction to hear the tax refund claims. The City argued that R.C. Ch. 2723, not

R.C. Ch. 718, set forth the exclusive statutory procedure for obtaining a refund of an allegedly 3

illegal tax. The City argued alternatively that even if R.C. Ch. 718 applied, any claims brought

under that section could not be filed directly in the common pleas court, but instead must be

brought in accordance with the administrative and judicial review scheme set forth in R.C. 718.11,

718.19, and R.C. 5717.011(B) which required that requests for a refund be filed with the tax

administrator and if those requests were denied, could be appealed to the local board of tax review.

{¶6} Following briefing by the parties, the Ohio Supreme Court issued a decision

denying the writ and concluding that the Taxpayers’ claims were not governed by R.C. Ch. 718

but instead were “substantively governed” by R.C. Ch. 2723, regardless of how the claims were

labeled or characterized in the amended complaint. State ex rel. Rittman v. Spitler, 2024-Ohio-

5668, ¶ 17 (“Spitler”). The Spitler Court concluded that,

Boler and Bise neither overpaid nor erred in how much they paid; rather, they fully paid an unauthorized and illegal tax bill. Properly characterized, their complaint seeks to have the 1.5 percent tax collected after 2007 declared illegal and to recover the funds that were collected through that illegal tax—which is precisely the type of action contemplated in R.C. 2723.01. R.C. 2723.01 endows common pleas courts of this state with authority to “enjoin the illegal levy or collection of taxes and assessments and entertain actions to recover them when collected.” Thus, Judge Spitler, a common-pleas court judge, has jurisdiction and authority to determine Boler and Bise's case, and we therefore decline to issue a writ of prohibition.

Spitler at ¶ 20. In reaching its conclusion, the Court also noted that the Taxpayers “might

encounter obstacles to recovery in other portions of R.C. Ch. 2723,” referring to the fact that “[the

Taxpayers] may have paid the illegally inflated tax bill without filing the required protest under

R.C. 2723.03.” Id. at ¶ 17, 18.

{¶7} After Spitler was issued, the City renewed its motion for summary judgment in the

trial court based on the Taxpayers’ failure to comply with the mandatory requirements of R.C.

2723.03, meaning the filing of “a written protest as to the portion sought to be recovered,

specifying the nature of [the] claim as to the illegality thereof, together with notice of [the] 4

intention to sue under sections R.C. 2723.01 to 2723.05[.]” On that same date, the City also

responded to the Taxpayers’ discovery requests. Following an unsuccessful attempt by the parties

to meet and resolve their discovery issues, the Taxpayers moved under Civ.R. 56(F) for additional

time to respond to the City’s motion for summary judgment. The trial court denied the motion.

The Taxpayers then opposed the City’s motion for summary judgment and at the same time moved

the trial court to compel the City to engage in discovery.

{¶8} Without ruling on the Taxpayers’ motion to compel, the trial court granted the

City’s motion for summary judgment, stating briefly as follows:

Based upon the Ohio Supreme Court decision in [Spitler], this Court is of the opinion this matter cannot proceed under R.C. §718.12 and [the Taxpayers] are unable to proceed under R.C. Chapter 2723. Therefore, [the City’s ] motion for summary judgment is granted and this matter is dismissed.

{¶9} The Taxpayers timely appealed and assert three assignments of error for our

review.

II.

ASSIGNMENT OF ERROR I:

THE TRIAL COURT ERRED IN GRANTING [THE CITY’S] MOTION FOR SUMMARY JUDGMENT AND DISMISSING THE CASE.

{¶10} The Taxpayers advance two arguments under their first assignment of error: 1) the

trial court ignored their R.C. 718.12 claims and ruled only on the Taxpayers’ arguments under

R.C. Ch. 2723; and 2) the trial court ignored the Taxpayers’ equitable claims of unjust enrichment

and money had and received. We disagree.

{¶11} The Taxpayers assert that R.C. Ch. 2723 is not the exclusive mechanism to recover

municipal income taxes, and because R.C. Ch. 718 is specific to the recovery of municipal income

taxes versus the general provisions of R.C. Ch.

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2025 Ohio 5780, Counsel Stack Legal Research, https://law.counselstack.com/opinion/boler-v-rittman-ohioctapp-2025.