Greene Cty. Agricultural Soc. v. Liming

In Greene Cty. Agricultural Soc. v. Liming, 89 Ohio St.3d 551, 2000 Ohio 486, 733 N.E.2d 1141, the Ohio Supreme Court set out the standard for sovereign immunity. "Ohio Rev. Code Ann. Ch. 2744 sets out the method of analysis, which can be viewed as involving three tiers, for determining a political subdivision's immunity from liability. First, Ohio Rev. Code Ann. 2744.02(A)(1) sets out a general rule that political subdivisions are not liable in damages. In setting out this rule, 2744.02(A)(1) classifies the functions of political subdivisions into governmental and proprietary functions and states that the general rule of immunity is not absolute, but is limited by the provisions of Ohio Rev. Code Ann. 2744.02(B), which details when a political subdivision is not immune. Thus, the relevant point of analysis (the second tier) then becomes whether any of the exceptions in 2744.02(B) apply. Furthermore, if any of 2744.02(B)'s exceptions are found to apply, a consideration of the application of Ohio Rev. Code Ann. 2744.03 becomes relevant, as the third tier of analysis." Id. at 556-557.