Ohio’s recent property tax reforms significantly limited school districts’ ability to challenge property valuations. Under those changes, districts could only file complaints when a property had transferred in an arm’s‑length sale before—but not after—the tax lien date. Districts were no longer permitted to selectively target properties they believed were undervalued absent a qualifying sale, nor could they appeal taxpayer‑favorable decisions issued by county boards of revision.
Most school districts adapted to these restrictions. However, several Central Ohio districts challenged the sale‑based limitation as unconstitutional. The Fifth District Court of Appeals upheld the statute, but the Tenth District Court of Appeals (Franklin County) has now reached the opposite conclusion, striking down the sale restriction. This split makes Ohio Supreme Court review highly likely. Until then, the Tenth District’s ruling is binding within Franklin County.
Practical Impact
The Tenth District’s decision effectively restores pre‑reform practices for school districts in Franklin County. Although the filing window for this year’s complaints has closed, we expect Franklin County districts to resume broad valuation challenges next year, unconstrained by the sale requirement.
Districts throughout Ohio may also begin filing challenges without a recent sale to preserve their rights should the Ohio Supreme Court ultimately affirm the Tenth District’s view. Importantly, the reforms’ separate prohibition on school district appeals of taxpayer‑favorable county‑level decisions remains intact statewide, limiting the extent of prolonged litigation.
Additional reforms enacted last summer were not addressed in the Tenth District’s ruling and continue to be litigated in other appellate districts.
Our Tax team will continue to monitor developments closely and provide updates as the Ohio Supreme Court takes up this issue.