State ex rel. Hollo v. Cuyahoga Cty. Council

2023 Ohio 4550, 231 N.E.3d 535
CourtOhio Court of Appeals
DecidedDecember 8, 2023
Docket113155
StatusPublished

This text of 2023 Ohio 4550 (State ex rel. Hollo v. Cuyahoga Cty. Council) 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
State ex rel. Hollo v. Cuyahoga Cty. Council, 2023 Ohio 4550, 231 N.E.3d 535 (Ohio Ct. App. 2023).

Opinion

[Cite as State ex rel. Hollo v. Cuyahoga Cty. Council, 2023-Ohio-4550.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE EX REL., JOSEPH P. HOLLO AND SUZANNE C. HOLLO, :

Relators, : No. 113155 v. :

CUYAHOGA COUNTY COUNCIL, :

Respondent. :

JOURNAL ENTRY AND OPINION

JUDGMENT: COMPLAINT DISMISSED DATED: December 8, 2023

Writ of Mandamus Motion No. 568405 Order No. 569514

Appearances:

Law Office of Harold E. Farling, LLC, and Harold E. Farling, for relators.

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, and Matthew T. Fitzsimmons IV, Assistant Prosecuting Attorney, for respondent.

MARY J. BOYLE, J.:

Relators, Joseph P. Hollo and Suzanne C. Hollo, seek a writ of

mandamus directing respondent, the Cuyahoga County Council (“County Council”), to approve a petition for annexation pursuant to R.C. 709.023 that sought to annex

a 72-acre parcel of property into the city of Berea. For the reasons that follow, we

grant County Council’s motion to dismiss and dismiss the complaint.

I. Background

On September 7, 2023, relators filed a complaint for writ of

mandamus. There, they alleged that they own a 72.552-acre parcel of land situated

in Olmsted Township that is abutted on three sides by property located within the

city of Berea. Relators filed petitions for expedited annexation of the property with

the Berea City Council and County Council pursuant to R.C. 709.023.

The Berea City Council passed an ordinance, Ordinance No. 2023-32,

on June 26, 2023, objecting to the petition and stating that the city of Berea would

not provide any services to the territory and would not maintain an adjacent road if

annexation created a segmentation or road maintenance issue. Citing to the Berea

ordinance of the nonprovision of services and a potential road service and

maintenance issue, County Council denied the petition by resolution on July 24,

2023. Relators then filed the instant complaint.

On October 6, 2023, County Council filed a motion to dismiss. There,

it argued that relators were not entitled to relief in mandamus because their petition

did not satisfy all the requirements for annexation found in R.C. 709.023(E).

Specifically, County Council argued that relators failed to satisfy R.C. 709.023(E)(6)

pertaining to an ordinance passed by the municipality that states what services

would be provided to the territory. County Council did not address or advance arguments related to any potential road issue under R.C. 709.023(E)(7). After an

extension of time, relators filed a brief in opposition on October 26, 2023. Relators

argued that County Council had no discretion to deny their petition because the

statute does not require a municipality to provide a minimum number of services in

order to satisfy R.C. 709.023(E)(6), only that a municipality must pass an ordinance

designating what services it would provide. County Council filed a reply brief on

November 1, 2023, reiterating its previous arguments.

II. Law and Analysis

A. Requirements for a Writ of Mandamus

To be entitled to a writ of mandamus, a relator is required to show

“that it has a clear legal right to the requested relief by showing that it satisfies the

conditions necessary for annexation.” State ex rel. Xenia v. Greene Cty. Bd. of

Commrs., 160 Ohio St.3d 495, 2020-Ohio-3423, 159 N.E.3d 262, ¶ 7, citing State ex

rel. Natl. Lime & Stone Co. v. Marion Cty. Bd. of Commrs., 152 Ohio St.3d 393,

2017-Ohio-8348, 97 N.E.3d 404, ¶ 26. For decisions pertaining to type-2

annexation proceedings, if a petitioner has satisfied the seven requirements in

R.C. 709.023(E), then a board of county commissioners, or in this case, County

Council, has no discretion to deny the petition. Id. at ¶ 4. Mandamus is an

appropriate means of requiring a county board of commissions to fulfill these

obligations imposed by statute. Id., citing R.C. 709.023(G).

The case is before this court on respondent’s motion to dismiss.

Pursuant to Civ.R. 12(B)(6), a court can dismiss a mandamus action “for failure to state a claim upon which relief can be granted if, after all factual allegations of the

complaint are presumed true and all reasonable inferences are made in the relator’s

favor, it appears beyond doubt that he can prove no set of facts entitling him to the

requested writ of mandamus.” State ex rel. Russell v. Thornton, 111 Ohio St.3d 409,

2006-Ohio-5858, 856 N.E.2d 966, ¶ 9.

B. Type-2 Annexation

Ohio’s statutory scheme for annexation includes three expedited

procedures, including a “type-2” annexation under R.C. 709.023. In this type of

annexation, all the landowners within the territory proposed for annexation agree

to the annexation and “‘the residents of the territory become residents of both the

township and the municipality, subject to the taxes of both, and potentially able to

receive services from either.’” Xenia at ¶ 3, quoting State ex rel. Butler Twp. Bd. of

Trustees v. Montgomery Cty. Bd. of Commrs., 112 Ohio St.3d 262, 2006-Ohio-6411,

858 N.E.2d 1193, ¶ 7, citing R.C. 709.023(H).

Under this procedure, in the absence of consent of the municipality,

a board of county commissioners must approve a type-2 annexation petition where

the petition complies with the seven conditions found in R.C. 709.023(E). If the

petition fails to meet any one of these conditions, it must be denied. Xenia, 160 Ohio

St.3d 495, 2020-Ohio-3423, 159 N.E.3d 262, at ¶ 4 (“A board of county

commissioners must grant a petition that satisfies all the conditions and must deny

a petition that does not.”). These seven requirements are: (1) The petition meets all the requirements set forth in, and was filed in the manner provided in, section 709.021 of the Revised Code.

(2) The persons who signed the petition are owners of the real estate located in the territory proposed for annexation and constitute all of the owners of real estate in that territory.

(3) The territory proposed for annexation does not exceed five hundred acres.

(4) The territory proposed for annexation shares a contiguous boundary with the municipal corporation to which annexation is proposed for a continuous length of at least five per cent of the perimeter of the territory proposed for annexation.

(5) The annexation will not create an unincorporated area of the township that is completely surrounded by the territory proposed for annexation.

(6) The municipal corporation to which annexation is proposed has agreed to provide to the territory proposed for annexation the services specified in the relevant ordinance or resolution adopted under division (C) of this section.

(7) If a street or highway will be divided or segmented by the boundary line between the township and the municipal corporation as to create a road maintenance problem, the municipal corporation to which annexation is proposed has agreed as a condition of the annexation to assume the maintenance of that street or highway or to otherwise correct the problem. As used in this section, “street” or “highway” has the same meaning as in section 4511.01 of the Revised Code.

R.C. 709.023(E)(1)-(7).

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Bluebook (online)
2023 Ohio 4550, 231 N.E.3d 535, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-hollo-v-cuyahoga-cty-council-ohioctapp-2023.