The Ohio Court of Appeals recently ruled on a case involving a group of taxpayers challenging the constitutionality of Ohio's income tax law. The court upheld a lower court's decision to dismiss the case due to lack of jurisdiction. This ruling affects the plaintiffs, who sought to overturn tax assessments and recover damages from the state.
The case, Allen v. Ohio Department of Taxation, was filed by John Allen and several co-plaintiffs in October 2025. They argued that the enforcement of Ohio Revised Code Section 5747.13 was unconstitutional. The plaintiffs claimed this law led to unlawful tax assessments and liens on their properties. They sought to have the law declared void, requested the state to stop enforcing it, and demanded substantial monetary damages totaling $297 million.
The Ohio Department of Taxation responded by filing a motion to dismiss the case, arguing that the Court of Claims did not have jurisdiction to hear the plaintiffs' constitutional claims. The state also noted that similar complaints had been previously filed by the same plaintiffs and dismissed for lack of jurisdiction. The lower court agreed with the state, dismissing the case without addressing the merits of the arguments presented.
In its ruling, the Ohio Court of Appeals, led by Judge Dingus, affirmed the lower court's decision. The court stated, "The Court of Claims lacks jurisdiction to resolve claims of unconstitutionality which give rise to the demand for relief." The court emphasized that while the plaintiffs framed their complaint in terms of fraud and trespass, the essence of their claims was a challenge to the state's enforcement of tax laws, which is not within the jurisdiction of the Court of Claims.
The court explained that the Court of Claims is designed to handle certain types of claims against the state, particularly those that could be brought against a private individual. However, since the plaintiffs' claims were rooted in constitutional challenges, they could not be addressed in that court. The court also noted that it cannot overturn judgments made by other courts, reinforcing the boundaries of its jurisdiction.
This ruling has significant implications for the plaintiffs and others who may consider challenging state tax laws. It reinforces the principle that constitutional claims must be pursued in appropriate forums and cannot be addressed in the Court of Claims. The court's decision highlights the limitations on the types of claims that can be brought against the state, particularly those involving constitutional issues.
Moving forward, the plaintiffs have limited options. They may seek to appeal the decision to a higher court, but it is unclear whether they will pursue that route. The court's ruling sets a precedent that could deter similar challenges against state tax laws in the future, as it clarifies the jurisdictional boundaries of the Court of Claims.
In summary, the Ohio Court of Appeals' decision in Allen v. Ohio Department of Taxation underscores the importance of understanding the jurisdictional limits of courts when challenging state laws. The ruling not only affects the plaintiffs in this case but also provides guidance for future litigants considering similar claims against the state.