2200 Carnegie, LLC v. Cuyahoga County Bd. of Revision

When a complaint has been filed that contests the county auditor’s valuation of a particular parcel, as it was in this case, and when that complaint asks for a value increase or reduction of $17,500 or more, Ohio Rev. Code 5715.19(B) requires that the auditor give notice of the complaint within thirty days of the last day for filing valuation complaints. At issue in this appeal was whether that notification is a prerequisite to the exercise of jurisdiction by the board of revision, and if so, whether the thirty-day deadline itself is jurisdictional. The Supreme Court held (1) under section 5715.19(B), the notification itself is jurisdictional, but the thirty-day requirement is not; and (2) thus, the original failure of the auditor in this case to give notice was cured when the notice was later given after remand by the court of common pleas. Because the court of appeals held the contrary, the Court reversed its decision.

2200 Carnegie, LLC v. Cuyahoga County Bd. of Revision