Background
John Allen and eight other plaintiffs sued the Ohio Department of Taxation in the Court of Claims, alleging that Ohio’s income-tax assessment and collection statute, R.C. 5747.13, was unconstitutional. They alleged that tax assessments and judgment liens entered against them under the statute amounted to fraud and trespass.
The plaintiffs sought to abolish the Ohio income tax, stop enforcement of R.C. 5747.13(C), vacate prior tax judgments, and recover $90 million in compensatory damages and $207 million in punitive damages. The Court of Claims dismissed for lack of subject-matter jurisdiction, without reaching the Department’s res judicata argument.
The Court’s Holding
The Tenth District affirmed. Although the complaint used tort labels and sought money damages, its substance challenged the constitutionality of R.C. 5747.13 and sought to nullify tax-related judgments entered by courts of common pleas.
The Court of Claims may hear claims against the state that could also be brought against a private citizen. It lacks jurisdiction, however, over constitutional claims and cannot overturn judgments issued by other courts. Because the requested relief depended on declaring the tax statute unconstitutional and undoing prior judgments, dismissal under Civ.R. 12(B)(1) was proper.
Key Takeaways
- Courts examine the substance of a complaint, not merely its tort labels or request for damages, when assessing jurisdiction.
- The Ohio Court of Claims cannot adjudicate constitutional challenges to state laws.
- The Court of Claims cannot vacate or otherwise overturn judgments issued by other courts.
Why It Matters
The decision reinforces the jurisdictional limits of Ohio’s Court of Claims. A plaintiff cannot bring a constitutional challenge there by styling the claim as fraud or trespass and requesting monetary relief.
Litigants seeking to challenge a statute’s constitutionality or attack an existing court judgment must pursue relief through a court with authority to decide those issues or through the appropriate direct-review process.