In State Dept. of Taxation v. Jones (1980), 61 Ohio St. 2d 99, 100-101, 399 N.E.2d 1215, a case remarkably similar to the present case, the Supreme Court of Ohio addressed the issues of lien priority and equitable subrogation. In Jones, Cleveland Federal Savings & Loan provided a loan to the Joneses that was secured by a mortgage. Cleveland Federal then provided a second loan that was secured by a mortgage on the same property as the first loan. The proceeds from the second loan were used to pay off the first loan (as well as additional judgment liens that had attached to the Joneses property). In between the time of the execution and the recording of the second mortgage, the State of Ohio Department of Taxation obtained a certificate of judgment lien that attached to the property subject to Cleveland Federal's mortgage. Jones, 61 Ohio St.2d at 99-100. Subsequently, the State filed a complaint in foreclosure against the real estate secured by Cleveland Federal's mortgage. Id. In answering the State's complaint, Cleveland Federal alleged that its mortgage had priority over the State's certificate of judgment lien pursuant to the doctrine of equitable subrogation. In rendering its decision, the Supreme Court of Ohio determined that Cleveland Federal's "own actions led to its dilemma of not obtaining the best priority lien." Jones, 61 Ohio St.2d at 102. Specifically, the court found that Cleveland Federal "was in complete control of the refinancing application ... controlled the disbursement of the funds, the filling out of all the forms, the date of the filing, and even the hiring of the title company." Jones, 61 Ohio St.2d at 102-103. Based upon these findings, the court held that it would not invoke the doctrine of equitable subrogation.