Cox v. Columbus Dept. of Bldg. & Zoning

2025 Ohio 1472
CourtOhio Court of Appeals
DecidedApril 24, 2025
Docket24AP-296
StatusPublished

This text of 2025 Ohio 1472 (Cox v. Columbus Dept. of Bldg. & Zoning) 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
Cox v. Columbus Dept. of Bldg. & Zoning, 2025 Ohio 1472 (Ohio Ct. App. 2025).

Opinion

[Cite as Cox v. Columbus Dept. of Bldg. & Zoning, 2025-Ohio-1472.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

Louise R. Cox, :

Plaintiff-Appellant, : No. 24AP-296 v. : (C.P.C. No. 23CV-7373)

City of Columbus Department of : (REGULAR CALENDAR) Building and Zoning et al., : Defendants-Appellees. :

D E C I S I O N

Rendered on April 24, 2025

On brief: The Behal Law Group LLC and John M. Gonzales, for appellant. Argued: John M. Gonzales.

On brief: Zachary M. Klein, City Attorney, Lara N. Baker- Morrish and Joshua M. Cartee, for appellees. Argued: Joshua M. Cartee.

APPEAL from the Franklin County Court of Common Pleas

BEATTY BLUNT, J.

{¶ 1} Plaintiff-appellant, Louise R. Cox, appeals the decision of the Franklin County Court of Common Pleas affirming the defendants-appellees, City of Columbus’ (“the City”) adjudication order granting variances to the city zoning code and permitting the building of a detached garage on a vacant lot next to Cox’s home. The owner of the vacant lot, nonparty Stephen Bollinger, had requested variances to build the garage as the R-3 District does not normally permit a garage as a principal use. The adjudication order authorized construction of a detached garage on the vacant lot, which was located across the street from Bollinger’s house at 299 Walhalla Road. Bollinger’s variance application indicated that he was renovating the home on his primary lot, that the garage exiting from the primary lot needed to be demolished as part of those renovations, and that a new garage No. 24AP-296 2

could not be built on the primary lot because it was inconsistent with the renovations and the geothermal system being installed. He indicated that the variance allowing the construction of a detached garage on the vacant lot would alleviate the hardship he was facing as a result of the renovations. {¶ 2} Cox owns the property adjacent to the vacant lot, and complained that the garage would not be compatible with the character of the area, was too close to her property line, and would block the site line for drivers negotiating the adjacent narrow alley. Notwithstanding her concerns, the Clintonville Area Commission unanimously recommended approving the requested variances, the Department of Building and Zoning Services accepted the Commission’s recommendation, and the City Council approved the variances on September 18, 2023. {¶ 3} Cox filed a timely appeal of the adjudication order to the Franklin County Court of Common Pleas on October 16, 2023, arguing that the order was “unconstitutional, illegal, arbitrary, capricious, unreasonable, or unsupported by the preponderance of substantial, reliable, and probative evidence on the whole record.” (Notice of Appeal from An Administrative Order No. CV23-045 at 1.) Her brief to the trial court asserted that there was “no hardship associated with the vacant lot to support a variance,” (Appellant’s Trial Brief at 3), and that the decision to approve the variances failed the “practical difficulties” test set forth in Duncan v. Village of Middlefield, 23 Ohio St.3d 83 (1986). Id. at 5-6. But the trial court concluded that based on its standard of review under R.C. 2506.04, the decision to grant the variances was “supported by the preponderance of substantial, reliable, and probative evidence. . . . [Cox] did not advance credible evidence that the City failed to properly perform its duties. Nor was there evidence that it acted unlawfully. . . . [The decision] was supported by a preponderance of the evidence in the record, and was not unconstitutional, illegal, arbitrary, capricious, or unreasonable.” (Apr. 8, 2024 Decision & Entry at 5-6.) This appeal followed, and Cox asserts a single assignment of error: The Trial Court erred by Affirming the City of Columbus’ Adjudication Order allowing numerous zoning variances.

In response, the City filed a combined motion to dismiss and merit brief, arguing that the “case is moot because construction on the Garage Lot has been completed and Appellant sought neither a stay of the City Council Decision nor an injunction against construction on No. 24AP-296 3

the Garage Lot.” (Combined Mot. to Dismiss and Merit Brief of Appellees’ at 14.) The City supported its mootness argument with photographs and affidavits from Bollinger and the Chief Building Official for the City of Columbus Department of Building and Zoning Services. See id. at Appendix, Ex. A (Aff. of Stephen J. Bollinger, Jr.) and Ex. B (Aff. of Amit B. Ghosh.) The City proceeded to argue that even if the case is not moot, the trial court’s judgment was correct because the City’s decision was “supported by a preponderance of substantial, reliable, and probative evidence” and is “not unconstitutional, illegal, arbitrary, capricious, or unreasonable.” (Combined Mot. to Dismiss and Merit Brief of Appellees at 17.) {¶ 4} We begin our analysis by observing that final orders of local administrative agencies, boards, and commissions may properly be appealed to the court of common pleas. See R.C. 2506.01(A). R.C. 2506.04 provides: If an appeal is taken in relation to a final order, adjudication, or decision covered by division (A) of section 2506.01 of the Revised Code, the court may find that the order, adjudication, or decision is unconstitutional, illegal, arbitrary, capricious, unreasonable, or unsupported by the preponderance of substantial, reliable, and probative evidence on the whole record. Consistent with its findings, the court may affirm, reverse, vacate, or modify the order, adjudication, or decision, or remand the cause to the officer or body appealed from with instructions to enter an order, adjudication, or decision consistent with the findings or opinion of the court.

R.C. 2506.04. This court has observed that “a review under R.C. 2506.04 is not de novo, [but] it often resembles a de novo proceeding because the reviewing court weighs the evidence in the ‘whole record’ in determining whether the administrative decision is supported by the preponderance of substantial, reliable, and probative evidence.” Homewood Corp. v. Dublin, 2014-Ohio-845, ¶ 9 (10th Dist.), citing Dudukovich v. Lorain Metro. Housing Auth., 58 Ohio St.2d 202, 206-207 (1979). But we have also held that the “court of common pleas should not substitute its judgment for that of an administrative board or agency unless the court finds that there is not a preponderance of reliable, probative and substantial evidence to support the decision.” One Neighborhood Condominium Assn. v. Columbus, 2017-Ohio-4195, ¶ 12 (10th Dist.), citing Kisil v. Sandusky, 12 Ohio St.3d 30, 34 (1984). While “the Court of Common Pleas must give due deference to the administrative resolution of evidentiary conflicts . . . the findings of the No. 24AP-296 4

agency are by no means conclusive.” (Internal quotations omitted). Id. Moreover, the party contesting a decision in an appeal under R.C. 2506.04 has the burden of showing that the underlying decision is erroneous. One Neighborhood at ¶ 13, citing Meyers v. Columbus, 2008-Ohio-3521, ¶ 7 (10th Dist.). And finally, R.C. 2506.04 limits this court’s review of trial court appeals on zoning decisions to “questions of law as provided in the Rules of Appellate Procedure and, to the extent not in conflict with those rules, Chapter 2505. of the Revised Code.” R.C. 2506.04. Accordingly, while “R.C. 2506.04 gives the common pleas court the authority to weigh the evidence, but the statute grants a more limited power to an appellate court to review the judgment of the common pleas court only on questions of law.” (Internal citations and quotations omitted). Ingram v. Bexley, 2015- Ohio-1011, ¶ 7 (10th Dist.).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Homewood Corp. v. Dublin
2014 Ohio 845 (Ohio Court of Appeals, 2014)
Meyers v. City of Columbus, 07ap-958 (7-15-2008)
2008 Ohio 3521 (Ohio Court of Appeals, 2008)
James A. Keller, Inc. v. Flaherty
600 N.E.2d 736 (Ohio Court of Appeals, 1991)
State ex rel. Wood v. Rocky River (Slip Opinion)
2021 Ohio 3313 (Ohio Supreme Court, 2021)
State ex rel. Burkons v. Beachwood (Slip Opinion)
2022 Ohio 748 (Ohio Supreme Court, 2022)
Dudukovich v. Lorain Metropolitan Housing Authority
389 N.E.2d 1113 (Ohio Supreme Court, 1979)
Kisil v. City of Sandusky
465 N.E.2d 848 (Ohio Supreme Court, 1984)
Duncan v. Village of Middlefield
491 N.E.2d 692 (Ohio Supreme Court, 1986)
Craig v. Gilchrist
2022 Ohio 4477 (Ohio Court of Appeals, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 1472, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cox-v-columbus-dept-of-bldg-zoning-ohioctapp-2025.