Save Ohio Parks v. Oil & Gas Land Mgt. Comm.

2025 Ohio 847
CourtOhio Court of Appeals
DecidedMarch 13, 2025
Docket24AP-206
StatusPublished
Cited by2 cases

This text of 2025 Ohio 847 (Save Ohio Parks v. Oil & Gas Land Mgt. Comm.) 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
Save Ohio Parks v. Oil & Gas Land Mgt. Comm., 2025 Ohio 847 (Ohio Ct. App. 2025).

Opinion

[Cite as Save Ohio Parks v. Oil & Gas Land Mgt. Comm., 2025-Ohio-847.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

Save Ohio Parks et al., :

Appellants-Appellants, : No. 24AP-206 (C.P.C. No. 23CV-8540) v. : (REGULAR CALENDAR) Oil & Gas Land Management : Commission, : Appellee-Appellee. :

D E C I S I O N

Rendered on March 13, 2025

On brief: Earthjustice, Megan M. Hunter, James Yskamp, Claire Taigman, Chris Tavenor, and Nathan Johnson, for appellants Save Ohio Parks, Backcountry Hunters & Anglers, Buckeye Environmental Council, and Ohio Environmental Council. Argued: Megan M. Hunter.

On brief: Dave Yost, Attorney General, Thomas J. Puckett, and Daniel Martin, for appellee. Argued: Daniel Martin.

APPEAL from the Franklin County Court of Common Pleas

BEATTY BLUNT, J.

{¶ 1} Appellants, Save Ohio Parks, Backcountry Hunters & Anglers, Buckeye

Environmental Council, and Ohio Environmental Council (“appellants”) appeal from a

decision of the Franklin County Court of Common Pleas granting the motion to dismiss

filed by appellee, Oil & Gas Land Management Commission (the “Commission”) pursuant

to Civ.R. 12(B)(1). For the following reasons, we affirm. No. 24AP-206 2

I. Facts and Procedural History

{¶ 2} Appellants filed an appeal in the Franklin County Court of Common Pleas

on November 30, 2023, seeking to challenge certain decisions of the Commission made

pursuant to R.C. 155.33, to approve nine nominations of land owned or controlled by a state

agency for the purpose of subjecting those lands to bidding for leasing to explore, develop

and/or produce oil and natural gas resources. (See generally Cert. Rec., Index #12, Notice

of Appeal.) Appellants claimed they should have been provided with an administrative

appeal pursuant to R.C. Ch. 119 but were not. Id.

{¶ 3} On December 29, 2023, the Commission filed a motion to dismiss for lack

of jurisdiction pursuant to Civ.R. 12(B)(1), asserting that R.C. Ch. 119 does not provide for

a right to appeal the decisions made by the Commission approving the nominations of land.

{¶ 4} On February 23, 2023, the trial court issued its decision and entry granting

the motion to dismiss filed by the [Commission] on December 29, 2023 and dismissing

appellants’ appeal. (Feb. 23, 2023 Decision & Entry.)

{¶ 5} This timely appeal to this court followed and is now before us.

II. Assignments of Error

{¶ 6} Appellants assert the following assignments of error for our review:

[1.] The Trial Court erred when it found that the Oil and Gas Land Management Commission’s approval of Nomination Nos. 23-DNR-0001, 23-DNR-0002, 23-DNR-0003, 23-DNR- 0004, 23-DNR-0005, 23-DNR-0006, and 23-DNR-0007 was not subject to appeal under R.C. 119.12 because these approvals were adjudicatory orders of a state agency performing a licensing function, providing subject matter jurisdiction to the Franklin County Court of Common Pleas to adjudicate the appeal pursuant to R.C. 119.12.

[2.] The Trial Court erred when it found the Appellants lacked standing because the Commission’s decision to approve the leasing of Salt Fork State Park and two state wildlife areas No. 24AP-206 3

without offering a hearing and without considering the mandatory decisional statutory factors has procedurally harmed Appellants and their members, and the Commission’s leasing approvals threaten Appellants’ members with concrete and particularized harms from the imminent oil and gas development of these state lands.

[3.] In the alternative, the Trial Court erred when it proceeded to decide the issue of whether Appellants had standing after the Trial Court had already determined it lacked subject matter jurisdiction over this matter.

III. Law and Analysis

A. Standard of Review

{¶ 7} When reviewing a judgment on a Civ.R. 12(B)(1) motion to dismiss for lack

of subject-matter jurisdiction, a de novo standard of review is employed. Pankey v. Ohio

Dept. of Rehab. & Corr., 2014-Ohio-2907, ¶ 7 (10th Dist.); Foreman v. Dept. of Rehab. &

Corr., 2014-Ohio-2793, ¶ 9 (10th Dist.), citing Perrysburg Twp. v. Rossford, 2004-Ohio-

4362, ¶ 5.

{¶ 8} Civ.R. 12(B)(1) requires dismissal where the trial court lacks jurisdiction over

the subject matter of the litigation. “Subject-matter jurisdiction involves ‘ “a court’s power

to hear and decide a case on the merits and does not relate to the rights of the parties.” ’ ”

Moore v. Ohio Dept. of Rehab. & Corr., 2019-Ohio-767, ¶ 4 (10th Dist.), quoting Robinson

v. Ohio Dept. of Rehab. & Corr., 2011-Ohio-713, ¶ 5 (10th Dist.), quoting Vedder v.

Warrensville Hts., 2002-Ohio-5567, ¶ 14 (8th Dist.).

{¶ 9} A court presented with a motion to dismiss for lack of subject-matter

jurisdiction must determine whether the complaint states any cause of action cognizable by

the forum. State ex rel. Bush v. Spurlock, 42 Ohio St.3d 77, 80 (1989); PNC Bank, Natl.

Assn. v. Botts, 2012-Ohio-5383, ¶ 21 (10th Dist.). Subject-matter jurisdiction is “a

condition precedent to the court’s ability to hear the case. If a court acts without No. 24AP-206 4

jurisdiction, then any proclamation by that court is void.” Pratts v. Hurley, 2004-Ohio-

1980, ¶ 11; State ex rel. Ohio Democratic Party v. Blackwell, 2006-Ohio-5202, ¶ 8. In

deciding a motion to dismiss for lack of subject-matter jurisdiction, the trial court may

consider evidence outside of the complaint. Brown v. Ohio Tax Commr., 2012-Ohio-5768,

¶ 14 (10th Dist.), citing Cerrone v. Univ. of Toledo, 2012-Ohio-953, ¶ 5 (10th Dist.), citing

Southgate Dev. Corp. v. Columbia Gas Transm. Corp., 48 Ohio St.2d 211, (1976),

paragraph one of the syllabus.

B. First Assignment of Error

{¶ 10} In their first assignment of error, appellants contend that the trial court erred

when it found that the Oil & Gas Land Management Commission’s approval of the seven

nominations delineated above was not subject to appeal under R.C. 119.12 because these

approvals were adjudicatory orders of a state agency performing a licensing function,

bringing the matter within the ambit of R.C. 119 for purposes of subject-matter jurisdiction.

This contention has no merit.

{¶ 11} In the administrative appeals context, “[c]ourts of common pleas only have

‘such powers of review of proceedings of administrative officers and agencies as may be

provided by law.’ ” Clifton Care Ctr. v. Ohio Dept. of Job & Family Servs., 2013-Ohio-2742,

¶ 9 (10th Dist.), quoting Ohio Const., article IV, § 4. See also Midwest Fireworks Mfg. Co.,

Inc. v. Deerfield Twp. Bd. of Zoning Appeals, 91 Ohio St.3d 174, 177 (2001) (“The right to

appeal an administrative decision is neither inherent nor inalienable; to the contrary, it

must be conferred by statute.”). Thus, jurisdiction over an administrative appeal is

improper “unless granted by R.C. 119.12 or other specific statutory authority.” Abt v. Ohio

Expositions Comm., 110 Ohio App.3d 696, 699 (10th Dist. 1996). To determine whether

R.C. 119.12 or other statutory authority does or does not grant the common pleas court No. 24AP-206 5

jurisdiction over an appeal, the reviewing court must look to the language of the statutes

involved to determine legislative intent. Ikemefuna Nkanginieme v. Ohio Dept. of

Medicaid, 2015-Ohio-656, ¶ 16 (10th Dist.).

{¶ 12} Generally, “R.C. 119.12 only allows appeals of orders issued pursuant to an

adjudication.” Estep v. Ohio Dept.

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Bluebook (online)
2025 Ohio 847, Counsel Stack Legal Research, https://law.counselstack.com/opinion/save-ohio-parks-v-oil-gas-land-mgt-comm-ohioctapp-2025.