Gillis v. Delaware Cty. Bd. of Revision

2024 Ohio 5669, 259 N.E.3d 771
Procedural entryThis page is a short order in Gillis v. Delaware Cty. Bd. of Revision. Read the opinion of the Court — 246 N.E.3d 721
Ohio Court of Appeals·Decided December 2, 2024·No. 24 CAH 04 0021·Published

Opinion

[Cite as Gillis v. Delaware Cty. Bd. of Revision, 2024-Ohio-5669.]

COURT OF APPEALS DELAWARE COUNTY, OHIO FIFTH APPELLATE DISTRICT

MARK H. GILLIS, : JUDGES: : Hon. W. Scott Gwin, P.J. Plaintiff - Appellant : Hon. John W. Wise, J. : Hon. Craig R. Baldwin, J. -vs- : : DELAWARE COUNTY BOARD OF REVISION, : Case No. 24 CAH 04 0021 et al., : : Defendant - Appellees : OPINION

CHARACTER OF PROCEEDING: Civil Appeal from the Ohio Board of Tax Appeals, Case No. 2023-838

JUDGMENT: Affirmed

DATE OF JUDGMENT: December 2, 2024

APPEARANCES:

For Defendant- Appellant For Appellee Northpark Endeavors, LLC

KAROL C. FOX MATTHEW S. ZEIGER E. JOEL WESP LAUREN P. RUBIN Rich & Gillis Law Group, LLC Zeiger,Tigges & Little LLP 5747 Perimeter Dr., Suite 150 3500 Huntington Center Dublin, Ohio 43017 41 S. High Street Columbus, Ohio 43215 For Appellee Olentangy Appellee Tax Ohio Tax Commissioner KELLEY A. GORRY Rich & Gillis Law Group, LLC DAVID A. YOST 5747 Perimeter Dr., Suite 150 Ohio Attorney General Dublin, Ohio 43017 30 E. Broad St., 17th Floor Columbus, Ohio 43215 MICHAEL P. CAVANAUGH Assistant County Prosecutor 145 N. Union St., 3rd Floor P.O. Box 8006 Delaware, Ohio 43015 Delaware County, Case No. 24 CAH 04 0021 2

Baldwin, J.

{¶1} The appellant, Mark H. Gillis, appeals the decision of the Ohio Board of Tax

Appeals decision affirming the Board of Revisions decision to dismiss his complaint.

Appellees are Delaware County Board of Revision, Delaware County Auditor, Olentangy

Local Schools Board of Education, Ohio Tax Commissioner, and Northpark Endeavors

(“Appellee Northpark”). The relevant facts are as follows.

STATEMENT OF THE FACTS AND THE CASE

{¶2} The appellant filed a third-party complaint with the Delaware County Board

of Revision for tax year 2022, challenging the value of the property owned by Appellee

Northpark known as Northpark Place. The appellant sought an increase in the value of

Northpark Place from $42,167,700 to $84,184,500 based upon the purchase occurring

on September 30, 2022. The appellant substantiated his claim with a Press Release.

{¶3} The Board of Revision scheduled a hearing on the appellant’s complaint for

May 25, 2023. However, one week before the scheduled hearing, the Board of Revision

met in open session and dismissed the appellant’s complaint for failing to comply with

R.C. §5715.19(A)(6)(a). The Board of Revision noted in its decision that the appellant

challenged the statute on constitutional grounds and that it lacks authority to address

constitutional issues.

{¶4} On May 19, 2023, the Board of Revision issued its written decision

dismissing the appellant’s complaint.

{¶5} The appellant appealed the Board of Revision’s decision to the Board of

Tax Appeals. Delaware County, Case No. 24 CAH 04 0021 3

{¶6} On February 21, 2024, the Board of Tax Appeals held an evidentiary

hearing.

{¶7} At the hearing, a former employee of the Franklin County Auditor’s Office

and a Deputy Tax Commissioner with the Ohio State Department of Taxation testified.

He testified, in general, about his experience with auditors determining the true value in

money of every parcel in a county. Based upon the data collected, the witness estimated

properties recently sold were valued more than thirty percent below the recent sales price.

He also explained how the undervaluation of one property could lead to an increased tax

burden on other properties.

{¶8} At the conclusion of the hearing, the Board of Tax Appeals affirmed the

decision of the Board of Revision dismissing the appellant’s complaint. The Board did not

opine on the constitutionality issue.

{¶9} The appellant filed a timely notice of appeal and herein raises the following

seven assignments of error:

{¶10} “I. THE DECISION IS UNREASONABLE AND UNLAWFUL BECAUSE THE

BTA RELIED UPON REVISIONS TO R.C 5715.19(A)(6)(a) THROUGH 2022 Am. Sub.

H.B. 126 (“H.B. 126”) THAT VIOLATE BOTH THE U.S. CONSTITUTION AND THE OHIO

CONSTITUTION.

{¶11} “II. FACIALLY, AND AS APPLIED TO APPELLANT, THE REVISION TO

R.C. 5715.19(A)(6)(a) TO LIMIT THE FILING OF A BOARD OF REVISION COMPLAINT

ONLY UPON PROPERTY SUBJECT TO AN ARM’S-LENGTH SALE (the “Arm’s-Length

Sale Restriction”) VIOLATES THE UNIFORM RULE MANDATED BY ARTICLE XII,

SECTION 2 OF THE OHIO CONSTITUTION. Delaware County, Case No. 24 CAH 04 0021 4

{¶12} “III. FACIALLY, AND AS APPLIED TO APPELLANT, THE REVISION TO

R.C. 5715.19(A)(6)(a) TO LIMIT THE FILING OF A BOARD OF REVISION COMPLAINT

ONLY UPON PROPERTY SUBJECT TO AN ARM’S-LENGTH SALE OCCURRING

BEFORE, BUT NOT AFTER, THE APPLICABLE TAX LIEN DATE (THE “BEFORE BUT

NOT AFTER TAX LIEN DATE RESTRICTION”) VIOLATES THE UNIFORM RULE

MANDATED BY ARTICLE XII, SECTION 2 OF THE OHIO CONSITUTION.

{¶13} “IV. FACIALLY, AND AS APPLIED TO APPELLANT, THE ARM’S-LENGTH

SALE RESTRICTION VIOLATES APPELLANT’S RIGHT TO EQUAL PROTECTION OF

THE LAWS AS GUARANTEED BY THE 14TH AMENDMENT OF THE UNITED STATES

CONSTITUTION AND ARTICLE I, SECTION 2 OF THE OHIO CONSTITUTION.

{¶14} “V. FACIALLY, AND AS APPLIED TO APPELLANT, THE BEFORE BUT

NOT AFTER TAX LIEN DATE RESTRICTION VIOLATES APPELLANT’S RIGHT TO

EQUAL PROTECTION OF THE LAWS GUARANTEED BY THE 14TH AMENDMENT OF

THE UNITED STATES CONSTITUTION AND ARTICLE I, SECTION 2 OF THE OHIO

{¶15} “VI. FACIALLY, AND AS APPLIED TO APPELLANT, THE ARM’S LENGTH

SALE RESTRICTION VIOLATES APPELLANT’S RIGHT TO DUE PROCESS

GUARANTEED BY THE 14TH AMENDMENT OF THE UNITED STATES

CONSTITUTION AND HIS RIGHT TO DUE COURSE OF LAW GUARANTEED BY

ARTICLE I, SECTION 16 OF THE OHIO CONSTITUTION.

{¶16} “VII. FACIALLY, AND AS APPLIED TO APPELLANT, THE BEFORE BUT

NOT AFTER TAX LIEN DATE RESTRICTION VIOLATES APPELLANT’S RIGHT TO

DUE PROCESS GUARANTEED BY THE 14TH AMENDMENT OF THE UNITED STATES Delaware County, Case No. 24 CAH 04 0021 5

CONSTITUTION AND HIS RIGHT TO DUE COURSE OF LAW GUARANTEED BY

ARTICLE I, SECTION 16 OF THE OHIO CONSTITUTION.”

I., II., III.

{¶17} In the appellant’s first, second, and third Assignments of Error, the appellant

argues that the Arm’s-Length Sale Restriction and the Before But Not After Tax Lien Date

Restriction of R.C. §5715.19(A)(6)(a) violate the Uniform Rule of Article XII, Section 2 of

the Ohio Constitution. We disagree.

STANDARD OF REVIEW

{¶18} “When considering the constitutionality of a statute, [a reviewing] court

‘presume[s] the constitutionality of the legislation, and the party challenging the validity of

the statute bears the burden of establishing beyond a reasonable doubt that the statute

is unconstitutional.’ ” Dayton v. State, 2017-Ohio-6909, ¶12, quoting Wilson v. Kasich,

2012-Ohio-5367, ¶18. The party challenging the statute has “a ‘heavy burden’ when

attempting to overcome the presumption of constitutionality.” Dayton at ¶12.

ANALYSIS

{¶19} R.C. §5715.19(A)(6), in pertinent part, states:

The legislative authority of a subdivision, the mayor of a municipal

corporation, or a third party complainant shall not file an original complaint

with respect to property the subdivision or complainant does not own or

lease unless both of the following conditions are met: Delaware County, Case No. 24 CAH 04 0021 6

(a) If the complaint is based on a determination described in division

(A)(1)(d) or (e) of this section, the property was (i) sold in an arm’s

length transaction, as described in section 5713.03 of the

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Gillis v. Delaware Cty. Bd. of Revision, 2024 Ohio 5669, 259 N.E.3d 771 (Ohio Ct. App. 2024).

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