[Cite as State v. Senu-Oke,
2021-Ohio-2699.]
IN THE COURT OF APPEALS OF OHIO
SECOND APPELLATE DISTRICT
MONTGOMERY COUNTY
STATE OF OHIO :
:
Plaintiff-Appellee : Appellate Case No. 29045
:
v. : Trial Court Case No. 2020-EX-70101
:
EDWA D SENU-OKE : (Civil Appeal from
: Common Pleas Court)
Defendant-Appellant :
:
...........
OPINION
Rendered on the 6th day of August, 2021.
...........
ASHTON J. HOOD, Atty. Reg. No. 0099925, and CHRISTINE L. STAAB, Atty. Reg. No.
0087939, Assistant Attorney General, State of Ohio Department of Taxation, Collections
Enforcement Section, 30 East Broad Street, 14th Floor, Columbus, Ohio 43215
Attorneys for Plaintiff-Appellee
EDWA D SENU-OKE, 400 Bracey Way, Chesapeake, Virginia 23323
Defendant-Appellant, Pro Se
.............
DONOVAN, J.
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{¶ 1} Edwa D. Senu-Oke, judgment debtor, appeals pro se from an order of the
trial court which reversed a magistrate’s decision to stay a garnishment and which
released funds to the State of Ohio Department of Taxation (the “State”). We affirm the
judgment of the trial court.
{¶ 2} On July 24, 2020, the State filed a motion for an order of garnishment; the
trial court issued a notice to Senu-Oke on the same day. The notice informed Senu-Oke
that the court had issued an order in favor of the State directing that some of Senu-Oke’s
assets that were in the possession of the garnishee be used to satisfy his debt to the
State, which was based on the State’s judgment against Senu-Oke in Montgomery C.P.
No. 2016SCJ123808. The notice included a “request for hearing” form, which informed
Senu-Oke that, if he requested a hearing, the hearing would “be limited to a consideration
of the amount of your money, property, or credits, other than personal earnings, in the
possession or control of the indicated garnishee, if any, that can be used to satisfy all or
part of the judgment” owed to the State, and that “[n]o objections to the judgment itself
will be heard or considered at that hearing.”
{¶ 3} On August 11, 2020, Senu-Oke filed the request for hearing form. The form
did not list any reasons why Senu-Oke disputed the State’s right to garnishment. As
stated above, it contained the admonition that no objections to the judgment itself would
be heard or considered at that hearing.
{¶ 4} A brief garnishment hearing was held on September 15, 2020. At the
hearing, Senu-Oke testified that he was employed as a physician and that the State was
apparently “garnishing [his] money” for taxes owed to the State “for a year that [he] never
worked here or lived here.” According to Senu-Oke, he had informed the State multiple
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times “through letters” that he never lived or worked in Ohio in 2006, the year in question.
Senu-Oke also stated that he received notice by the mail “that they were going to pass
the judgment on me or had already passed the judgment on me,” but he “never had an
opportunity to dispute it or show them [his] proof,” even though he had sent his “proof.”
Senu-Oke stated that, in his correspondence to the State, he had informed it that he had
lived in a different state and had paid taxes to that state, and even sent a copy of the
check he wrote to that state (Delaware). He stated that he “also brought every single
billing … for that year,” and indicated that he had “billed only in the State of Delaware
because that’s where I lived and worked.” Senu-Oke stated that the last time he lived in
Ohio was when he was in medical school in 2002. The magistrate indicated that she
“would like to get copies” of these documents so she could look at them and try to sort
the matter out. The magistrate instructed Senu-Oke to proceed to another room to make
copies of his original evidence for her to review. In response to a question from Senu-
Oke, the magistrate told Senu-Oke that it was up to him to decide which documents to
submit to establish that he was not a resident of the State and was not working in Ohio in
2006, and Senu-Oke indicated his understanding.
{¶ 5} On September 18, 2020, the magistrate issued a decision stating that Senu-
Oke had “introduced documents to establish he was not working in Ohio during the time
frame the State of Ohio claims he owes taxes.” The magistrate stayed the garnishment,
ordered the clerk of courts to hold the funds until further order of the court, and gave the
State 14 days to submit documents that established the basis for the taxes owed.
{¶ 6} The State filed objections on October 2, 2020. The State asserted that the
documentation that Senu-Oke introduced at the hearing effectively sought to invalidate
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the prior judgment by showing that he was working outside of Ohio during the assessment
period. The State argued in its objections that the prior judgment was valid, Senu-Oke’s
due process rights had been met, and the court of common pleas lacked jurisdiction to
stay the execution of the pending action.
{¶ 7} Specifically, the State asserted that certified service of the notice of
assessment had been delivered and signed on May 14, 2008, pursuant to R.C. 5703.37,
“along with instructions on how to petition for reassessment and request a hearing.”
Pursuant to R.C. 5747.13(B), an assessment becomes final unless the party assessed
files a written petition for reassessment within 60 days after service of the notice of
assessment. The State points out that Senu-Oke “petitioned for reassessment” on July
25, 2008, which was 72 days after the notice of assessment was delivered, and the Tax
Commission dismissed the petition for reassessment as not timely filed. According to
the State, Senu-Oke appealed to the Ohio Board of Tax appeals, pursuant to R.C.
5717.02, arguing that he was not an Ohio resident during the relevant time period, but
“offered no evidence the tax [c]ommissioner’s decision regarding service of assessment
was incorrect.” According to the State, the tax commissioner filed a motion to affirm or
dismiss, arguing that “the Tax Commissioner was correct in dismissing the petition for
reassessment because it was filed untimely or, in the alternative, [Senu-Oke’s] notice of
appeal failed to state with specificity the errors complained of.” On April 26, 2011, the
Board of Tax Appeals unanimously affirmed the tax commissioner’s decision dismissing
the appeal as untimely filed. (The Board of Tax Appeals’ decision and order was
attached to the State’s objections.) The State further asserted that, pursuant to R.C.
5717.04, decisions of the Board of Tax Appeals “may be appealed directly to the Ohio
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Supreme Court as of right, to the Court of Appeals where the taxpayer resides, or to the
Franklin County Court of Appeals (in specified circumstances).”
{¶ 8} The State also directed the court’s attention to R.C. 5747.13(C), which
provides:
After an assessment becomes final, if any portion of the assessment
remains unpaid, including accrued interest, a certified copy of the tax
commissioner's entry making the assessment final may be filed in the office
of the clerk of the court of common pleas in the county in which the
employer's, taxpayer's, or qualifying entity's place of business is located or
the county in which the party assessed resides. If the party assessed is
not a resident of this state, the certified copy of the entry may be filed in the
office of the clerk of the court of common pleas of Franklin county.
Immediately upon the filing of the entry, the clerk shall enter a
judgment against the party assessed in the amount shown on the entry. …
The judgment shall have the same effect as other judgments. Execution
shall issue upon the judgment upon the request of the tax commissioner,
and all laws applicable to sales on execution shall apply to sales made
under the judgment.
{¶ 9} According to the State, R.C. 5747.13 “thus empowers the Tax Commissioner
to issue assessments for taxes due. The taxpayer is required to be served written notice
of the assessment and is provided multiple levels of appeal, being permitted to appeal to
the Tax Commissioner, the Board of Tax Appeals, the Court of Appeals and the Ohio
Supreme Court.” The State asserted that assessments “which become final are certified
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to the clerk of the court of common pleas, and the clerk then records a judgment against
the party assessed for the amount shown due. The State asserted that it had complied
with the provisions of R.C. 5747.13, and Senu-Oke had been afforded due process to
contest this assessment.
{¶ 10} Because the statutory process had been followed, the State asserted in its
objections that the magistrate did not have the authority to vacate an order of the Ohio
Department of Taxation. The State directed the court’s attention to R.C. 5703.38, which
provides: “No injunction shall issue suspending or staying any order, determination, or
direction of the department of taxation, or any action of the treasurer of state or attorney
general required by law to be taken in pursuance of any such order, determination, or
direction. This section does not affect any right or defense in any action to collect any
tax or penalty.”
{¶ 11} The State further directed the court’s attention to Hakim v. Kosydar, 49 Ohio
St.2d 161,
359 N.E.2d 1371 (1977). According to the State, the common pleas court
“lacks jurisdiction to revisit the underlying judgment,” and “execution on the garnishment
must be permitted to move forward.” Finally, the State asserted that Senu-Oke was not
precluded from bringing his due process arguments in other proceedings; he was simply
precluded from seeking the dismissal or vacation of the judgment lien “in the manner
sought herein.”
{¶ 12} A copy of the State’s 2008 notice of assessment issued to Senu-Oke and a
signed U.S. Postal Service receipt for the May 14, 2008 delivery of the notice were
attached to the State’s objections; the receipt bore the signature of Charlton Senu-Oke
and a Honeybrook Avenue address in Dayton.
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{¶ 13} Senu-Oke did not respond to the objections.
{¶ 14} On February 24, 2021, the trial court determined that Senu-Oke was
“effectively seeking to invalidate or dismiss the underlying judgment lien through improper
means,” and that the court lacked jurisdiction to suspend or stay an order of the
Department of Taxation.” Thus, the State’s the objections were sustained. The court
stated:
After review of the record, it appears to this Court that [Senu-Oke]
has incorrectly attempted to attack the validity of the judgment lien itself,
rather than utilize lack of notice as a defense to the collection action. The
court notes that during the hearing held by [the magistrate] … [Senu-Oke]
stated that he received notice many months later, and as a result, could not
dispute the assessment despite having conveyed to the State of Ohio that
he never lived or worked there. However, the possible assertion of such a
notice defense is unclear from the record currently before this Court.
While [Senu-Oke] cannot attack the validity of the judgment lien itself
and have it vacated, he is free to raise the claim that he never received
notice of the tax assessment as an affirmative defense to defend against
the collection action. … State v. Lomaz, 146 Ohio App.3d 376, 379,
766
N.E.2d 209 (11th Dist.2001). “A trial court has jurisdiction to consider
affirmative defenses raised in a motion during a collection proceeding. If
such a defense is raised, the state’s attempt at collection is not stayed, but
proceeds to final judgment, and if the defense is good, judgment will be
entered for the taxpayer.” (Citation omitted). Id.
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[Senu-Oke] is entitled to raise affirmative defenses to oppose action
taken by [t]he State to collect on that judgment. See Lomaz, supra.
However, as indicated above, the possible assertion of such an affirmative
defense is unclear from the record currently before this Court. What is
clear from the record is that [Senu-Oke] is attempting to vacate the
judgment lien and stay the department from proceeding with collection.
…
Based on the language in the Magistrate’s Decision, it appears that
the decision to stay the garnishment was not based on the affirmative
defense of lack of notice, rather, it was based upon [Senu-Oke’s] challenge
to the validity of the underlying judgment lien. The record before this Court
reveals that [Senu-Oke] seeks to have the tax judgment against him
vacated just as the tax payer did in Hakim.
As such, this Court must conclude that the Magistrate’s decision
staying the garnishment and ordering the Clerk of Court to hold the funds
held until further order is improper. R.C. 5747.13 requires a taxpayer to
pursue a challenge with the tax commissioner. [Senu-Oke’s] challenge of
the underlying tax liens is impermissible and he is precluded from seeking
dismissal of the judgment lien in such a manner.
{¶ 15} Thus, the court refused to adopt the magistrate’s decision and ordered that
the garnishment funds be released to the State.
{¶ 16} Senu-Oke asserts the following assignment of error on appeal:
THE JANUARY 27, 2021 DECISION OF THE [TRIAL COURT]
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SHOULD BE REVERSED BECAUSE IT ERRONEOUSLY IGNORED THE
AFFIRMATIVE DEFENSE OF INSUFFICIENT NOTICE RAISED BY
APPELLANT AT THE SEPTEMBER 15, 2020 HEARING ….
{¶ 17} In his brief, Senu-Oke recounts the evidence that he presented at the
garnishment hearing about not having lived at the service address and not having resided
in Ohio since he was a medical student in 2002. He points out that the State’s own
records and the trial court’s decision (in a footnote) acknowledge that he was served at
an Ohio address and that service was signed for by a different person, not Senu-Oke.
Senu-Oke argues that the trial court “ignored” his affirmative defense of insufficient notice,
and that he had been “unable to raise an objection to the incorrect tax assessment within
the time period specified under law precisely because of the State’s own improper notice.”
Senu-Oke asserts that the trial court erred and encourages this court to “exercise
jurisdiction” over the underlying tax dispute, direct the Board of Taxation to re-open the
matter, and provide him with an opportunity to contest the validity of the tax assessment,
noting that that R.C. 5717.04 provides that final determinations of a local board of tax
review can be appealed to the supreme court or relevant court of appeals.
{¶ 18} The State responds that, in 2007, it received notice from the Internal
Revenue Service of a federal tax filing made by Senu-Oke using the address at
Honeybrook Avenue in Dayton, Ohio. Upon review, the State discovered that Senu-Oke
had failed to file personal income taxes with the State of Ohio during the 2006 tax year.
According to the State, R.C. 5747.13(C) “fully comports with all due process
requirements” insofar as taxpayers are given notice of the assessment, including
instructions on how to appeal such an assessment. According to the State, citing R.C.
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5703.05, even if a taxpayer does not avail himself or herself of the administrative appeal
process, the taxpayer can pay the tax assessed and then timely file an application for a
refund, “which enables the taxpayer to be heard as to all challenges pertaining to the tax.”
The State asserts that “[d]ue process concerns involving State statutory tax schemes are
treated differently than general due process requirements” and that Ohio’s statutory
process satisfies due process.
{¶ 19} The State asserts that Senu-Oke was not entitled to service of a notice of
judgment, but he had notice that a judgment could be filed against him. The State directs
our attention to R.C. 5703.51(C), which provides:
With or before the issuance of an assessment, the tax commissioner or
county auditor shall provide to the taxpayer:
(1) A written description of the basis for the assessment and any penalty
required to be imposed with the assessment;
(2) A written description of the taxpayer's right to appeal the assessment
and an explanation of the steps required to request administrative review
by the tax commissioner;
(3) A written description of the collection remedies available to the state,
including a statement that if the taxpayer fails to pay an assessment within
sixty days after it is due, the tax commissioner will certify the amount to the
attorney general for collection, and a summary of the provisions contained
in section 131.02 of the Revised Code.
{¶ 20} The State asserts that the notice issued to Senu-Oke informed him that his
failure to act could result in the filing of a judgment, and that the assessment would
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become final 60 days after receipt of the assessment and would be sent to the Attorney
General’s Collection Enforcement Section. According to the State, the Attorney General
is required by R.C. 131.02(B) “to give immediate notice by mail or otherwise to the party
indebted of the nature, amount and other information related to the debt, including that
‘[t]he attorney general shall collect the claim or secure a judgment and issue an execution
for its collection. R.C. § 131.02(C).’ ” The State asserts that, while “no notice of judgment
is required,” taxpayers receive at least two written notices that a judgment may be taken
on the outstanding debt: the initial notification of the assessment and appeal process and
when the debt is certified to the Ohio Attorney General.
{¶ 21} The State asserts that the notices of assessment in this case were properly
served prior to judgment. The State gave written notice of the assessment in the manner
provided in R.C. 5703.37, including instructions on how to petition for reassessment and
request a hearing on the petition. The State asserts that R.C. 5747.13(A) authorizes the
tax commissioner to issue an assessment against any taxpayer who fails to file a return
or fails to pay the income tax owed, and the taxpayer is given written notice via certified
mail sent to the last known address of the taxpayer. According to the State, the certified
service of the notice of the assessment was delivered to the same address used by Senu-
Oke in his 2006 federal tax filing and signed for by Charlton Senu-Oke on May 14, 2008.
{¶ 22} The State asserts that Senu-Oke did not timely appeal the assessments
with the tax commissioner, noting that Senu-Oke’s appeal was filed 72 days after service
was certified. Thus, his appeal was appropriately denied and a final order was issued
by the tax commissioner. The State asserts that Senu-Oke’s claim that he was not
provided an opportunity to appeal the assessments prior to judgment “is simply not true.”
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The State notes that R.C. 5703.056(A) “requires the tax commissioner to use certified
mail or personal service,” and R.C. 5703.056(B)(4) authorizes the tax commissioner to
use a delivery service for the delivery of any payment or document that records
electronically to a database kept in the regular course of its business the date on which
the payment or document was given by the delivery service to the person who signed the
receipt of delivery and name of the person who signed by receipts.” The State asserts
that Exhibit B reflects that certified mail was delivered to Senu-Oke’s presumed address
in Dayton on May 14, 2008, signed by Charlton Senu-Oke.
{¶ 23} The State argues that R.C. 5747.24 governs Senu-Oke’s claim that he was
not an Ohio resident during the tax periods in question. R.C. 5747.24 provides:
(B)(1) Except as provided in division (B)(4) of this section, an individual is
presumed to be not domiciled in this state for the entirety of any taxable
year for which the individual files a statement with the tax commissioner
under division (B)(2) of this section and meets all of the following
requirements:
…
(c) The individual did not hold a valid Ohio driver's license or identification
card at any time during the taxable year. An individual shall not be deemed
to have held a valid Ohio driver's license or identification card for the
purposes of this division if, before the beginning of the taxable year, the
individual surrendered the license or card to the bureau of motor vehicles
or to the motor vehicle licensing authority of a jurisdiction outside this state.
…
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…
(2) On or before the fifteenth day of the tenth month following the close of
the taxable year, an individual that meets the requirements prescribed by
division (B)(1) of this section may file with the tax commissioner, on the form
prescribed by the commissioner, a statement from the individual verifying
that the individual meets such requirements.
{¶ 24} The State asserts that Exhibit C, attached to its brief, indicates that in
October 2003, Senu-Oke renewed his driver’s license using the same address that was
used for notice of the assessment (the Honeybrook Avenue address), and that his driver’s
license did not expire until October 29, 2007. Thus, during the assessment year (2006),
Senu-Oke still had a valid driver’s license using that address, and he was presumed under
Ohio law to be an Ohio resident pursuant to R.C. 5747.24. Furthermore, Senu-Oke
specifically stated in his brief that he had no affiliation with the State of Ohio after 2002,
but his renewal of his Ohio driver’s license in 2003 “directly conflicts” with that assertion.
{¶ 25} We note that in Lomaz, 146 Ohio App.3d 376, 379,
766 N.E.2d 209, cited
by the trial court, the Eleventh District quoted R.C. 2723.01, which states: “Courts of
common pleas may enjoin the illegal levy or collection of taxes and assessments and
entertain actions to recover them when collected, without regard to the amount thereof,
but no recovery shall be had unless the action is brought within one year after the taxes
or assessments are collected.” The Lomaz court further quoted R.C. 5703.38, which
states: “No injunction shall issue suspending or staying any order, determination, or
direction of the department of taxation, or any action of the treasurer of state or attorney
general required by law to be taken in pursuance of any such order, determination, or
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direction. This section does not affect any right or defense in any action to collect any
tax or penalty.”
{¶ 26} The Eleventh District noted as follows:
In construing these two provisions together, the Supreme Court of
Ohio has held that “R.C. 5703.38 prohibits a Court of Common Pleas from
entering an order which has the effect of suspending or staying an order,
determination, or direction of the Department of Taxation.” Hakim v.
Kosydar, (1977), 49 Ohio St.2d 161,
3 O.O.3d 211,
359 N.E.2d 1371,
syllabus. See, also, Torbet v. Kilgore (1966), 6 Ohio St.2d 42,
35 O.O.2d
48,
215 N.E.2d 579, paragraph one of the syllabus (holding that “Section
5703.38, Revised Code, prohibits an injunction that will suspend or stay any
order, determination or decision of the Tax Commissioner”).
In Hakim, the taxpayer did not specifically request injunctive relief;
rather, she asked the trial court to vacate a judgment lien that had followed
a final sales tax assessment on the grounds of insufficient service of
process. The Supreme Court rejected the taxpayer's argument, reasoning
that although R.C. 5703.38 did not appear to prevent an action to vacate a
tax judgment, if a court were to vacate such a judgment, the Attorney
General could not maintain an action to collect upon the judgment or to
enforce the judicial lien. Hakim at 164-165 …. Stated differently, Hakim
stands for the “proposition that a court has no power to entertain a complaint
to vacate a judgment rendered upon a tax assessment before collection
proceedings are instituted, because judgment on that complaint would
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amount to an injunction against future collection proceedings in violation of
R.C. 5703.38.” Ohio Dept. of Taxation v. Plickert (1998), 128 Ohio App.3d
445, 449,
715 N.E.2d 239.
The Supreme Court also observed that the effect of R.C. 5703.38
would not result in an absolute denial to courts of the right to determine the
legality of a tax. Hakim at 165 …. Instead, a taxpayer who disputes the
final determination of a tax commissioner may appeal that decision to a
Board of Tax Appeals, and from there directly to the Supreme Court. Id.
Furthermore, a taxpayer may pay the assessment, seek a certificate of
abatement, and raise any due process arguments at that time.
Id. More
important for this case, “It should also be noted that [the taxpayer] can await
the institution of collection proceedings … and therein raise as a defense
her claim of insufficient service of the assessment.” Hakim at 165 ….
In Plickert, we embraced the Supreme Court's holding and similarly
concluded that R.C. 5703.38 prohibited a court of common pleas from
entering any order that would amount to an injunction against future
collection proceedings. Plickert at 449, 715 N.E.2d 239. However, this
court also relied upon the Supreme Court's cautionary language when we
held the following:
“This dictum recognizes the trial court's general jurisdiction to enter
judgment upon an affirmative defense raised in the collection proceeding,
which was left undisturbed. If such a defense is raised, the state's attempt
at collection is not stayed, but proceeds to final judgment, and if the defense
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is good, judgment will be entered for the taxpayer. While it is true that
granting judgment for the debtor for defects in the service of process in this
manner has the practical effect of precluding collection efforts, this is not
accomplished by the court's equitable power of injunction. Therefore,
neither R.C. 5703.38 nor Hakim prohibits a court from considering this
defense in the context of an action to collect upon a judgment for delinquent
tax.” (Emphasis added.) Plickert at 450, 715 N.E.2d 239. See, also, State
v. Marysville Steel, Inc. (1997), 119 Ohio App.3d 785,
696 N.E.2d 298.
In light of the foregoing, we conclude that the trial court correctly
overruled appellant's motion to vacate the judgment lien. Precedent from
both the Supreme Court of Ohio and this court is very clear in holding that
R.C. 5703.38 limits a court's power to enter an injunction or take similar
action that would prevent the Attorney General from entertaining future
collection proceedings.
Having said that, unlike Hakim, the present case was an action to
collect a tax and is, therefore, not affected by R.C. 5703.38. Here, the state
has attempted to collect on a valid judgment lien by garnishing appellant's
personal property through attaching his bank accounts with Firstar. As a
result, while appellant could not attack the validity of the judgment lien itself
and have it vacated, he was free to raise the claim that he had never
received notice of the tax assessment as an affirmative defense to defend
against the collection action. Plickert, supra.Lomaz at 378-379.
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{¶ 27} As in Lomaz, the State herein attempted to collect on a lien valid by
operation of law. R.C. 5747.13(B) provides:
Unless the party assessed files with the tax commissioner within sixty days
after service of the notice of assessment, either personally or by certified
mail, a written petition for reassessment, signed by the party assessed or
that party's authorized agent having knowledge of the facts, the assessment
becomes final, and the amount of the assessment is due and payable from
the party assessed to the commissioner with remittance made payable to
the treasurer of state. …
(Emphasis added.)
{¶ 28} As noted above, the form by which Senu-Oke requested a hearing stated:
“No objections to the judgment itself will be heard or considered at that hearing.” While
Senu-Oke argues that he raised the affirmative defense of lack of notice of the
assessment at the garnishment hearing, the magistrate apparently concluded that he was
attempting to attack the validity of the lien. The magistrate did not address any alleged
lack of notice of the 2008 notice of assessment. When asked if his documentation was
“all about the taxes for 2006,” Senu-Oke responded affirmatively. The magistrate
advised Senu-Oke to provide “whatever it is that you feel is indicative that … you don’t
owe taxes here.” In her written decision, the magistrate noted that Senu-Oke introduced
evidence establishing that he was not working in Ohio in 2006. She further ordered the
State “to provide an accounting to Judgment Debtor establishing the amount owed,” an
amount already established by the final lien. The trial court found that Senu-Oke sought
to have the tax judgment against him vacated.” We agree. In sustaining the State’s
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objections, the trial court correctly concluded that the magistrate’s decision staying the
garnishment and ordering the clerk to hold the funds until further order was improper.
{¶ 29} Senu-Oke’s assignment of error is overruled.
{¶ 30} The judgment of the trial court is affirmed.
.............
WELBAUM, J. and EPLEY, J., concur.
Copies sent to:
Ashton J. Hood
Christine L. Staab
Edwa D Senu-Oke
Hon. Gerald Parker
