The Ohio Court of Appeals has upheld a lower court's decision to dismiss a lawsuit filed by Michael J. Young against the Franklin County Treasurer. Young claimed that the Treasurer's office failed to remove an expired tax lien certificate from property records, which he argued caused him financial losses. This ruling is significant as it reinforces the legal protections afforded to government entities under Ohio law.
The case, Young v. Franklin County Treasurer, was filed on July 9, 2026, under docket number 25AP-826. It centers around a dispute involving a tax lien certificate that Young claimed had expired. The court's ruling affects Young and potentially others in similar situations who may seek to challenge government actions related to property tax liens.
Background
Michael J. Young, acting as a trustee, initiated the lawsuit against the Franklin County Treasurer and Franklin County itself. The dispute began when Nelnet, Inc. acquired a tax lien certificate on a property in Franklin County in 2009. After Nelnet ceased enforcement of the lien, Young transferred his interest in the property to Plaza East, Inc., a corporation he wholly owned, in 2018.
Young alleged that he repeatedly contacted the Treasurer's office to have the expired tax lien removed from the property’s tax bills. However, the Treasurer's office refused to do so, which led to complications when Plaza East attempted to sell the property in November 2024. The sale fell through because a title agency would not insure the title due to the outstanding tax lien certificate. Consequently, Young filed a complaint in the Franklin County Court of Common Pleas on January 31, 2025, seeking a declaratory judgment to have the lien declared expired and void. The trial court agreed and issued an order on March 24, 2025, declaring the lien expired.
The Ruling
Despite the favorable ruling regarding the lien's status, Young's subsequent lawsuit sought damages against the Treasurer’s office for alleged misconduct. The Franklin County Court of Common Pleas granted the Treasurer's motion to dismiss on September 30, 2025, citing that Young had failed to adequately plead his case. The court stated that Young did not provide sufficient facts to give the Treasurer fair notice of the nature of the tortious actions he was pursuing.
The court noted, "Plaintiff fails to state what legal duty Defendant breached. Accordingly, the Court finds the Plaintiff has not adequately pleaded operative facts sufficient to give fair notice of the nature of . . . whatever tortious action he’s pursuing."
Furthermore, the court determined that the Treasurer and Franklin County were entitled to statutory immunity under Ohio Revised Code Chapter 2744, which protects government entities from liability in many cases. The court's decision emphasized the lack of a legal duty that the Treasurer breached, which was a crucial factor in the dismissal.
Impact
This ruling reinforces the legal principle that government entities enjoy a degree of protection from lawsuits, particularly in cases involving their official duties. It highlights the importance of adequately pleading a legal claim and providing sufficient factual details in complaints against government officials. The ruling may deter similar lawsuits from individuals who do not meet the legal standards required to challenge government actions.
Young's case serves as a reminder that while individuals have the right to seek redress in court, they must do so with a clear understanding of the legal obligations and immunities that protect government entities. The ruling may also influence how future cases involving tax liens and government actions are approached in Ohio.
What's Next
Details were not available in the court filing regarding whether Young plans to appeal the decision. However, given the court's clear ruling on the sufficiency of the complaint and the statutory immunity, an appeal may face significant challenges.