Board of Commissioners v. City of Lebanon

The central issue before us in this case is whether the *190amended provisions of R.C. 709.16, effective June 7,1986 (H.B. No. 981), are applicable to action by the board of commissioners on the three amended annexation petitions filed with the board by the city on April 16,1986. For the reasons which follow, we answer such query in the negative and thus affirm the court of appeals, albeit on different grounds.

The lower courts approached this issue by analyzing whether H.B. No. 981 changed R.C. 709.16 in a manner which affected “substantive” rights, and is thus applicable only prospectively, or…