Prows v. Oxford

Ohio Court of Appeals·Decided September 8, 2026·No. CA2026-01-015·Published

Opinion

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO BUTLER COUNTY

TATE DAVID PROWS, et al., :

CASE NO. CA2026-01-015

Appellant, :

OPINION AND

vs. : JUDGMENT ENTRY 9/8/2026

CITY OF OXFORD, :

Appellee. :

:

CIVIL APPEAL FROM BUTLER COUNTY COURT OF COMMON PLEAS Case No. CV 2025 06 1430

Green & Green, Lawyers, and Jared A. Wagner and Jane M. Lynch, for appellee. Tate David Prows, pro se.

OPINION

BYRNE, P.J.

{¶ 1} Appellant, Tate David Prows, appeals pro se the decision of the Butler County Court of Common Pleas granting the Civ.R. 12(C) motion for judgment on the pleadings filed by appellee, the City of Oxford. For the reasons outlined below, we affirm the common pleas court's decision.

I. Facts and Procedural History

{¶ 2} Tate Prows, along with his parents, Ann and David Prows (collectively, the "Prowses"), own and operate a family-run short-term rental business. The business rents properties located in the City through online platforms such as Airbnb. The City is a municipal corporation located in Butler County, Ohio.

{¶ 3} On August 3, 2021, the City repealed the prior version and adopted a new version of Oxford Cod.Ord. Chapter 183, titled "HOTEL, SHORT-TERM RENTAL AND CONVENTION TAX." The new version imposed a 3% lodging excise tax on hotels and short-term rentals within the City, as authorized by R.C. 5739.091. The ordinance's stated purpose was to provide additional funds to the City and its housing trust fund, also known as its affordable housing fund. The new version defined "short-term rental" as:

any establishment offering at least one but less than five rooms for the accommodation of guests, which is rented for a fee for less than thirty (30) consecutive days, whether such rooms are in one or several structures.

Oxford Cod.Ord. 183.01(e).

{¶ 4} On June 5, 2025, the Prowses filed both an initial complaint and an amended complaint against the City. The amended complaint challenged the constitutionality of the new Oxford Cod.Ord. Chapter 183, arguing that the Ohio Constitution did not permit the tax on short-term rentals and that the proceeds from that tax could not be used for the City's housing trust fund. Based on these arguments, the Prowses sought: (1) a declaratory judgment that the new short-term rental tax was unconstitutional and unenforceable as to the Prowses' property; (2) a declaration that the ordinance violated Article VIII, Section 16 of the Ohio Constitution by providing for the deposit of funds received through the short-term rental tax into the City’s affordable housing fund; (3) a permanent injunction prohibiting the City from enforcing the

ordinance's short-term rental tax; and (4) restitution of the short-term rental taxes the Prowses had paid to the City following the tax's enactment, under the theories of unjust enrichment and money had and received.

{¶ 5} On September 23, 2025, the City filed a Civ.R. 12(C) motion for judgment on the pleadings. To support its motion, the City argued that well-established black-letter law permitted it to levy taxes, including a short-term rental tax, under its powers of local self-government provided by the Home Rule Amendment to the Ohio Constitution, Article XVIII, Section 3. The City also argued that it was constitutionally permissible to deposit the funds it obtained from that tax into its affordable housing fund. The common pleas court agreed and, on January 23, 2026, entered judgment granting the City's Civ.R. 12(C) motion for judgment on the pleadings and dismissing the Prowses' claims against the City with prejudice.1

{¶ 6} In so holding, the common pleas court noted:

The Court finds that Oxford Cod. Ord. 183 is constitutional and enforceable against [the Prowses] and further finds that current Ohio Supreme Court precedent has recognized that municipalities such as the City may impose taxes pursuant to their powers of local self-government granted by the Home Rule Amendment of the Ohio Constitution, Article XVIII, Section 3.

The common pleas court also noted:

The Court further finds that the City is permitted to deposit funds obtained from the short-term rental tax into its Affordable Housing Fund and that such actions do not violate Article III, Section 16 of the Ohio Constitution. The Court concludes that, under its interpretation of Article XVIII, Section 3 of the Ohio Constitution, the City's use of revenue from the short-term rental tax to its Affordable Housing Fund is permissible.

1. The common pleas court also denied motions for summary judgment and for judgment on the pleadings filed by the Prowses. The court's decision with respect to those motions, however, is not a part of this appeal.

II. Tate Prows' Appeal and Two Assignments of Error

{¶ 7} On January 30, 2026, Tate Prows (hereinafter, "Prows") filed a notice of appeal from the common pleas court's decision.2 After the parties' briefing and the conclusion of oral argument, Prows' appeal was submitted to this court for consideration and is now properly before this court for decision. To support his appeal, Prows has raised two assignments of error, challenging certain aspects of the common pleas court's decision to grant the City's Civ.R. 12(C) motion for judgment on the pleadings. We address each of Prows' two assignments of error more fully below. Before addressing Prows' two assigned errors, however, we will first set forth the proper standard of review and the legal principles applicable to this appeal.

A. De Novo Standard of Review Applies

{¶ 8} "A trial court's decision on a Civ.R. 12(C) motion for judgment on the pleadings is reviewed by an appellate court de novo." Elboco Ents. v. Billman, 2020-Ohio- 4877, ¶ 18 (12th Dist.). "De novo means that this court uses the same standard that the common pleas court should have used." Boehm v. Ohio Dept. Pub. Safety, 2025-Ohio- 5092, ¶ 8 (12th Dist.). "Therefore, when conducting a de novo review, this court independently reviews the trial court's decision without giving it any deference." Colwell v. Bob & Shawn Ents., LLC, 2026-Ohio-976, ¶ 16 (12th Dist.). That is, under a de novo standard of review, "we examine the legal questions with fresh eyes, giving no deference to the trial court's conclusions." Smith v. Mercy Health-Clermont Hosp., LLC, 2025-Ohio- 1590, ¶ 13 (12th Dist.).

2. We note that, rather than all three of the Prowses executing their own notices of appeal, it was only Tate Prows who executed the notice of appeal filed in this case. Therefore, because one pro se litigant cannot file a notice of appeal on behalf of another, see Hineman v. Brown, 2003-Ohio-926, ¶ 2 (11th Dist.), there is just one appellant in this case rather than three. That being, Tate Prows.

B. Civ.R. 12(C) Motion for Judgment on the Pleadings Standard

{¶ 9} "Pursuant to Civ.R. 12(C), after the pleadings are closed but within such time as not to delay the trial, any party may move for judgment on the pleadings." Fields v. Van Ee, 2026-Ohio-2926, ¶ 13 (12th Dist.). "'Civ.R. 12(C) motions are specifically for resolving questions of law.'" State ex rel. Conomy v. Rohrer, 2025-Ohio-5296, ¶ 22, quoting State ex rel. Midwest Pride IV, Inc. v. Pontious, 1996-Ohio-459, ¶ 21. To that end, "[d]ismissal is appropriate under Civ.R. 12(C) when (1) the court construes as true, and in favor of the nonmoving party, the material allegations in the complaint and all reasonable inferences to be drawn from those allegations and (2) it appears beyond doubt that the plaintiff can prove no set of facts that would entitle him or her to relief." Reister v. Gardner, 2020-Ohio-5484, ¶ 17.

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