State ex rel. Kirkpatrick v. Madison Twp.

2025 Ohio 5591
CourtOhio Court of Appeals
DecidedDecember 8, 2025
Docket25CA2
StatusPublished

This text of 2025 Ohio 5591 (State ex rel. Kirkpatrick v. Madison Twp.) 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. Kirkpatrick v. Madison Twp., 2025 Ohio 5591 (Ohio Ct. App. 2025).

Opinion

[Cite as State ex rel. Kirkpatrick v. Madison Twp., 2025-Ohio-5591.]

IN THE COURT OF APPEALS OF OHIO FOURTH APPELLATE DISTRICT PICKAWAY COUNTY

: State ex rel. Kirkpatrick, et al., : : Plaintiffs-Relators-Appellants : Case No. 25CA2 and Cross-Appellees, : : v. : : Madison Township, Ohio, et al., : : DECISION AND JUDGMENT Defendants-Respondents- : ENTRY Appellees and Cross-Appellants. : : RELEASED 12/8/2025 _____________________________________________________________ APPEARANCES:

Kathleen F. Ryan and Hanna R. Puthoff, Wood & Lamping LLP, Cincinnati, Ohio for Plaintiffs-Relators-Appellants and Cross-Appellees.

Paul-Michael La Fayette and Ashley B. Hetzel, Freeman, Mathis & Gary LLP, Columbus, Ohio for Defendants-Respondents-Appellees.

Joseph R. Miller, Danielle S. Rice, Elizabeth S. Alexander, and Garrett M. Anderson, Vorys, Sater, Seymour and Pease LLP, Columbus, Ohio for Defendants-Respondents-Appellees and Cross-Appellants.

Hess, J.

{¶1} Kyle Kirkpatrick appeals the judgment of the Pickaway County Court

of Common Pleas dismissing his claims under Civ.R. 12(B)(6) for failure to state a

claim upon which relief can be granted. Kirkpatrick raises two assignments of error.

First, he contends that the trial court erred when it dismissed his declaratory

judgment claim because a valid rezoning did not occur. He argues that (1) a valid

written resolution and (2) the correct identification of acreage is required for there

to be a valid rezoning, and the township trustees did not adopt a valid resolution Pickaway App. No. 25CA2 2

with accurate acreage. Second, he contends that the trial court erred when it

dismissed his claims for injunctive relief and damages. He argues that these claims

were dismissed because the underlying claims were dismissed and when the trial

court’s dismissal on those claims is reversed, the dismissal of his injunctive and

damage claims should be reinstated. Kirkpatrick raises no error with the trial court’s

decision dismissing his mandamus claim.

{¶2} The appellees argue the trial court correctly found that a written

resolution is not required by the zoning statute and the correct acreage was

consistently identified. And, because the injunctive and damages claims are not

standalone claims, the dismissal of Kirkpatrick’s other claims means that the trial

court properly found that those claims must also be dismissed.

{¶3} Certain appellees have filed a cross appeal contending that even

though the trial court granted their motion to dismiss under Civ.R. 12(B)(6), the trial

court should have dismissed the complaint for lack of subject matter jurisdiction

under Civ.R. 12(B)(1) because the case was moot. They argue that the trial court

improperly placed the burden of proof of this issue upon CTR, but that regardless

of the improper burden-shifting, CTR proved that construction on the rezoned

property has already commenced.

{¶4} We find that Kirkpatrick’s claims are moot. The trial court should have

dismissed them under Civ.R. 12(B)(1) for lack of subject matter jurisdiction, instead

of dismissing them for failure to state a claim under Civ.R. 12(B)(6). We sustain

cross appellants’ first assignment of error. We dismiss cross appellants’ remaining

assignment of error and dismiss Kirkpatrick’s appeal in its entirety. Pickaway App. No. 25CA2 3

I. FACTS AND PROCEDURAL BACKGROUND

{¶5} In May 2022, CTR1 applied to Madison Township to have two

parcels2 (239.24 acres) (the “Property”) rezoned from RR, Rural Residential,

Rickenbacker Impact Zone to RBD, Rickenbacker Business Development.

According to the application, the Property owner, Scarbrough Farms, was in

contract to sell 239.24 acres to CTR and gave authority for the rezoning

application. The application identified the Property acreage as “239.240” and

stated that CTR planned to “construct class-A industrial warehouse/manufacturing

facilities. This is consistent with the RBD zoning district and other projects Madison

Township zoned RBD." A map attached to the application identified the two parcels

by parcel number and identified the estimated total acreage as “237.44 +/-.”

{¶6} In July 2022, the Madison Township zoning commission held a public

meeting to discuss the rezoning and in August 2022, the zoning commission voted

to approve the rezoning. The approval stated that it approved “to rezone 239.240

acres . . . from Rural Residential to Rickenbacker Business District . . . .” A legal

description “for a 239.240 acre tract” was signed by the surveyor and included as

an exhibit to the zoning commission’s approval. On August 30, 2022, the Madison

Township Trustees voted to approve the rezoning of the 239.24 acres.

{¶7} In the fall of 2022, after the Madison Township Trustees approved

the rezoning, Kirkpatrick, who opposed the rezoning, attempted to place a

1 For simplicity and because the distinctions have no legal relevance for our purposes, we refer to

the developer defendants collectively as CTR, which was also the trial court’s collective reference for them. The developer defendants named in the first amended complaint are CTR Partners, LLC (which was improperly named as CT Realty, LLC) and W-CTR Scarbrough Land Holdings VIII, L.L.C. 2 The two parcels were Parcel Number F1600010006001 and Parcel Number F1600010005900. Pickaway App. No. 25CA2 4

referendum about the rezoning on the ballot for the electors of Madison Township.

Kirkpatrick filed the referendum petition with the Pickaway County Board of

Elections. However, in November 2022, Scarbrough Farms, the Property owner,

filed a protest with the Board of Elections, in which it explained that the zoning

referendum proposed by Kirkpatrick violated R.C. 519.12(H) because it contained

a material omission, was misleading, and failed to include an appropriate map. On

January 4, 2023, the Board of Elections agreed with Scarbrough Farms, upheld

the protest, and dismissed Kirkpatrick’s referendum petition.

{¶8} On August 27, 2024, two years after the Madison Township Trustees

approved the rezoning of the Property and a year and a half after the Board of

Elections rejected his referendum petition, Kirkpatrick filed a complaint in the

Pickaway County Court of Common Pleas in which he sought to have the rezoning

of the Property declared illegal, null, and void. Kirkpatrick sued Madison Township,

the Madison Township Zoning Inspector, and the Madison Township Board of

Trustees for the actions they took in approving the rezoning (the Township

defendants), Scarbrough Farms (the former Property owner), CT Realty, and

various W-CTR Scarbrough Land Holding companies (the rezoning applicant and

developer). Several months later, Kirkpatrick filed an amended complaint to correct

the names of the necessary parties and to reflect that Scarbrough Farms had

transferred the Property. Kirkpatrick voluntarily dismissed Scarbrough Farms. In

the proceedings below, the parties and the trial court referred to the parties in their

collective groups as Kirkpatrick, Township, and CTR, and for ease and consistency

we do likewise. Pickaway App. No. 25CA2 5

{¶9} The Township and CTR filed motions to dismiss the complaint under

Civ.R. 12(B)(1) and 12(B)(6).3 CTR argued that under Civ.R. 12(B)(1), the trial

court lacked jurisdiction over Kirkpatrick’s claims because they are moot. CTR

provided evidence that it had invested more than $23 million in the Property,

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Bluebook (online)
2025 Ohio 5591, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-kirkpatrick-v-madison-twp-ohioctapp-2025.