[Until this opinion appears in the Ohio Official Reports advanc e sheets, it may be cited as Electronic Classroom of Tomorrow v. State Bd. of Edn. , Slip Opinion No. 2021-Ohio-3445.]

NOTICE This slip opinion is subject to f ormal revision before it is pu blished in an advance sheet of the Ohio Official Reports. Readers are reques ted to promptly notify the Reporter of Decisions, Supreme Court of Ohi o, 65 South Front Street, Columbus, Ohio 43215, of any typographical or other formal errors in the opinion, in order that corrections may be made before the opinion is published.

S LIP O PINION N O
. 2021-O HIO -3445
E LECTRONIC C LASSROOM OF T OMORROW , A PPELLANT , v . O HIO S TATE B OARD

OF E DUCATION ET AL ., A PPELLEES
. [Until this opinion appears in t he Ohio Official Reports advanc e sheets, it may be cited as Electronic Classroom of Tomorrow v. State Bd. of Edn. , Slip Opinion No. 2021-Ohio-3445.] Education—Community schools—Ohio St ate Board of Education’s final determination that a community school must repay money in excess funding may not be appealed under R.C. C hapter 119—Court of appeals’ judgment affirmed. (No. 2020-0182—Submitted Marc h 2, 2021—Decided October 5, 2021. )
A PPEAL from the Court of Appeal s for Franklin County, No. 17AP-767, 2019-Ohio-1540.

________________ D E W INE , J. {¶ 1} When a charter school is found to owe money to the state of Ohi o based on a review of the school’s enrollment data, a statute al lows the charter schoolS UPREME C OURT OF O HIO

2 to appeal that decision to the O hio State Board of Education fo r an informal hearing on the matter. R.C. 3314.08(K)(2)(b). The same statute provid es that “[a]ny decision made by the board [on such an appeal] is final.” R.C. 3314.08(K)(2)(d). The question for this case is whe ther a party may appeal this “ final” decision. {¶ 2} We hold that there is no right to appeal such a decision. R.C. 3314.08 uses “final” in the ordinary sen se of the word, indicating that the matter is at an end. We thus affirm the court of app eals’ judgment dismissing the ca se. I. Background {¶ 3} Before closing its doors in 2018, the Electronic Classroom of Tomorrow (“ECOT”) was Ohio’s largest charter school. 1 State ex rel. Electronic Classroom of Tomorrow v. Cuyahoga Cty. Court of Common Pleas , 129 Ohio St.3d 30, 2011-Ohio-626, 950 N.E.2d 149, ¶ 2. It was the state’s fir st online charter school and, like other public schools, r elied on state funding. Id. A. The Ohio Department of Education determines that ECOT owes some $60
million to the state {¶ 4} In 2016, the Ohio Department of Education conducted a review of
student enrollment at ECOT and determined t hat the state had ov erpaid the charter school approximately $60 million. T his finding was premised on the department
of education’s determination that ECOT was required to provide its students with five hours of learning opportun ities per day, and an examinatio n of log-in and logout data which revealed that, on average, students remained onl ine for one hour a day. {¶ 5} The review of ECOT’s enrollment data was conducted pursuant to the department of education’s au thority under R.C. 3314.08(K) (“the enrollment1. In common parlance, a school like ECOT is typically referre d to as a “charter school.” The Revised Code uses the term “community school.” R.C. 3314.01(B) . This opinion uses the terms interchangeably.January Term, 2021

3 review statute”). That statute enables the department of educa tion to perform an
initial review of a charter school ’s enrollment to make sure th e school received the right amount of funding. R.C. 3314.08(K)(3). If the departmen t of education determines that a community school owes money to the state, the n the school may appeal that determination to t he state board. R.C. 3314.08(K)( 2)(a). On appeal,
the state board “shall conduct an informal hearing on the matte r” and “shall issue a decision” following the hearing. R.C. 3314.08(K)(2)(b). The s tate board’s decision is “final.” R.C. 3314.08(K)(2)(d).
B. ECOT seeks to challe nge the state board’s decision {¶ 6} After the department of education made its determination that E COT received too much funding and needed t o repay the state, ECOT e xercised its right to appeal to the state board. The state board considered the a ppeal and issued a decision largely confirming the de partment of edu cation’s deter mination and ordering a return of $60,350,791. {¶ 7} ECOT proceeded to simultaneously institute two different action s in an attempt to challenge the state board’s “final” determination . It filed at the Franklin County Court of Common Pleas an administrative appeal of the state board’s determination, arguing th at the enrollment-review statu te’s reference to “final” meant the determination was appealable. (This matter i s the subject of the present appeal.) And it filed an original action seeking writs of mandamus and prohibition in this court, under the alternative theory that an extraordinary writ was available because the enrollment-review statute did not provide a right to appeal
the state board’s “final” decisi on. The state board moved to d ismiss the original action. It argued that an extrao rdinary writ was improper beca use ECOT had an adequate remedy at law by way of the administrative appeal, and that, setting aside the adequate-remedy issue, ECO T failed to allege any claims jus tifying relief. We granted the state board’s motion and dismissed the original act ion withoutS UPREME C OURT OF O HIO

4 specifying our rationale. 2 State ex rel. Electronic Cla ssroom of Tomorrow v. State Bd. of Edn. , 150 Ohio St.3d 1426, 2017-Ohio-7567, 81 N.E.3d 1268. {¶ 8} As for ECOT’s administrative appeal, the common pleas court granted a motion to dismiss, concluding that it lacked jurisdic tion to entertain the appeal because the enrollment-review statute denominated the st ate board’s determination as “final.” The Tenth District Court of Appeals initially reversed but, on reconsideration, affirmed the trial court’s decision. It turned both to its own precedent, which had understood “f inal” agency decisions to be nonappealable, and
to our decision in Brookwood Presbyterian Church v. Ohio Dept. of Edn. , 127 Ohio St.3d 469, 2010-Ohio-5710, 940 N.E.2d 1256, where we said an ag ency’s “final”
decision under a different statut e was appealable only because another provision of
that same statute specifically granted a right to appeal. {¶ 9} ECOT has now appealed the court of appeals’ judgment affirming the
trial court’s dismissal order. We must determine whether the e nrollment-review statute allows ECOT to appeal t he state board’s “ final” determi nation. II. Under a plain reading of the enrollment-review statute, th e final decision
of the state board is not subject to appeal {¶ 10} Not all orders issued by administrative agencies—even ones that are denoted as final—are subject to appeal. Our Constitution provi des that the courts of appeals shall have “such jur isdiction as may be provided by law” to review administrative decisions. Ohio Constitution, Article IV, Secti on 3(B)(2). And while R.C. 2505.03(A) grants appella te jurisdiction for “[e]ver y final order * * * of a court,” it grants appellate jurisdiction over “the final orde r of any administrative * * * agency” only “when provided by law.” Thus, the question in this case is

2. Although we did not specify our rationale for granting the motion to dismiss, it is clear after our decision today that a party who seeks to challenge a decision o f the state board in a 3314.08(K)(2)(b) proceeding by way of an extraordinary writ will satisfy the lac k-of-an-adequate-remedy-at-law requirement.January Term, 2021

5 whether there is a statutory grant of jurisdiction that would a llow ECOT to appeal the finding of the state board. {¶ 11} R.C. 119.12(B) is Ohio’s general provision spelling out the rig ht to appeal an agency adjudication. T his statute tells us that “[a] ny party adversely affected by any order of an agency * * * may appeal to the cour t of common pleas of Franklin county.” R.C. 3301.13— the general provision establ ishing the department of education and the state board—provides that in th e exercise of its powers, the department of education—and by extension the state board, see R.C. 3301.01—shall be subject to R.C. Chapter 119. However, a more specific provision that limits a party’s ability to appeal trumps these general pr ovisions. {¶ 12} The enrollment-review statute establishes procedures for the department of education to issu e findings for the recovery of e xcess funding based upon a review of a community school’s enrollment data and for a community school to challenge those findings by appe aling to the state board. T here is no question that the enrollment-review statute is a more specific statute t han R.C. 119.12(B) as
to the matter at issue. So we must determine whether a fair re ading of the enrollment-review statute precludes ECOT from appealing the sta te board’s final
determination. {¶ 13} Our analysis starts with the enrollment-review statute, and specifically what it means when it says that the state board’s determination following an informal hearing is “final.” ECOT argues that the word “final” should be understood as a legal term of a rt, meaning that the state bo ard’s decision is subject to an appeal. The state board disagrees; it says “fina l” should be understood in the everyday sense of the wor d, marking the end of the road thus rendering the state board’s decision nonappealab le. We share the state board ’s view. {¶ 14} The ordinary meaning of “final,” of course, is something that is “n ot to be altered or undone.” Webster’s Third New International Dictionary 851 (1986). A parent ends the discussion with his child upon sayin g, “I’ve made myS UPREME C OURT OF O HIO

6 decision and my decision is final.” A contestant on Who Wants to be a Millionaire locks in her answer choice only upon affirming that it’s her “f inal answer.” Likely, you’re out of luck if you intend to return an item to a store t hat posted a sign saying:
“All sales are final.” {¶ 15} ECOT’s argument is premised on the fact that sometimes in the l egal context, labeling something as “final” also imparts an additional meaning to the word. Sometimes we use “final” as a legal term of art to indic ate the point at which proceedings before one court are complete, and the matter may b e appealed to a higher court. In Ohio, a “final order” is one that may be appe aled to a higher court.
See R.C. 2505.02. And in the federal system, a “final judgment” i s one that may be appealed. Mohawk Industries, Inc. v. Carpenter , 558 U.S. 100, 106, 130 S.Ct. 599, 175 L.Ed.2d 458 (2009); see also 28 U.S.C. 1291 (granting the courts of appeals jurisdiction over appeal s from “all final decisions of the district courts”). In this vein, Black’s Law Dictionary defines “final” when used to refer to “a judgment at law” as “not requiring any further j udicial action by the court tha t rendered judgment to determine the matter litigated; concluded. * * * Once an order, judgment, or decree is final, it may be appealed on the merits.” (Emphasis added.) Black’s Law Dictionary 773 (11th Ed.2019). {¶ 16} In determining the meaning of “final” within the enrollment-rev iew statute, we look first to the pla in language of the statute, re ad in context. The statute creates a two-step review of the public funding a community sch ool has received, first by the department of educa tion and then by the state boar d on appeal. Step one involves the department of ed ucation’s initial review. R.C . 3314.08(K)(1). If the department of education de termines a community school recei ved too much funding, the “community school ma y appeal the department’s dete rmination to the
state board of education or its designee.” R.C. 3314.08(K)(2)( a). {¶ 17} An appeal of the department of e ducation’s determination leads to the second step: the state board ’s determination of the appeal following an informalJanuary Term, 2021

7 hearing on the matter. R.C. 3314.08(K)(2)(b) and (c). Unlike the department of education’s initial finding, the s tate board’s determination in the second step is not designated as appealable. R.C. 3314.08(K)(2)(d). Instead, we are told, “[a]ny decision made by the [state] boa rd under [the enrollment-review statute] is final.”
Id

. {¶ 18} By explicitly designating the department of education’s initial decision as appealable but not t he state board’s final decision as such, it is evident that the General Assembly meant only for the department’s initi al decision to be subject to an appeal. Why would the General Assembly hide the ball about the supposed appealability of the stat e board’s decision after plai nly stating in R.C. 3314.08(K)(2)(a) that the departme nt of education’s decision is appealable? Sticking with the ever yday meaning of “final” offers a far less puzzling result. {¶ 19} This reading is reinforced when one contrasts the way “final” i s used in the enrollment-review statute with the way it is typically u sed when meant as a legal term of art. When “final” is used to specify the point i n time in which an order may be appealed to a higher court, it is a modifying word. Thu s, legal texts speak of “final order[s],” see R.C. 2505.02, “final decisions,” see 28 U.S.C. 1291, and “final judgment[s],” Mohawk Industries , 558 U.S. at 106, 130 S.Ct. 599, 175 L.Ed.2d 458. Here though, the enrollme nt-review statute doesn’ t say that the state board’s decision is a “final order” or “final decision”; it sim ply says that the board’s order is “final.” Thus, a fair r eading of the enrollment-revie w statute leads to the conclusion that the General Assembly did not use “final” as a l egal term of art to
indicate that the state board ’s decision under R.C. 3314.08(K)( 2)(b) or (c) is appealable, but rather in the or dinary sense of the word. {¶ 20} ECOT insists that had the state legislature meant to foreclose appellate review of t he state board’s deci sion, it would have u sed language like “final and not appealable.” I n support, it points to other par ts of the Revised Code where such language has been employed. See, e.g. , R.C. 3311.0510(A) (“TheS UPREME C OURT OF O HIO

8 superintendent’s order is final and is not appealable”); R.C. 3 316.03(E) (“A determination by the auditor of state * * * is final and conclu sive and not appealable”); R.C. 3318.051(E) (“Any decision by the commission * * * is final and not subject to appeal”). But this argument is easily defea ted when one considers that the legislature has also sometimes labeled order s as “final and subject to appeal.” See, e.g. , R.C. 3769.0810(I) (a decision by the state racing commission to impose certain assessments is “final” and subject to appeal under R.C. 119.12); R.C. 3905.14(G) (a decision by the superintendent of insurance to issue a ceaseand-desist order is a “final order [that] may be appealed”); R. C. 3905.50(F) (“All
final orders and decisions of th e superintendent [of insurance] are subject to judicial review as provided in Chapter 119. of the Revised Code”); R.C. 4731.23(E) (a decision by the state medical boa rd is “final * * * except that the license or certificate holder may appeal in the manner provided by Chapter 119. of the Revised Code”); see also Brookwood , 127 Ohio St.3d 469, 2010-Ohio-5710, 940 N.E.2d 1256, at ¶ 24 (Brown, C.J., dissenting) (citing other examples). So the
enrollment-review statute’s standalone reference to “final” in no way necessitates ECOT’s reading. III. Caselaw supports our plain reading of the enrollment-revi ew statute {¶ 21} If there is any doubt that this plain reading is the correct interpretation of “final” in the enrollment-review statute, it is removed when one
looks to our caselaw. We start with Brookwood . That case also concerned the meaning of “final,” though in a d ifferent statute about applyin g to be a sponsor of a community school. See R.C. 3314.015. Only certain entities may qualify as sponsors, like tax-exempt, “edu cation-oriented” entities. R.C. 3314.02(C)(1)(f). Brookwood Presbyterian Church app lied for sponsorship status, b ut the department of education rejected Brookwood’s application because it determ ined that the
church was not “education-oriented.” Brookwood at ¶ 2. Former R.C. 3314.015(B)(3)—relisted now as R.C. 3314.015(B)(4)—denoted the state board’sJanuary Term, 2021

9 finding as to an entity’s “education-oriented” status as “final .” However, R.C. 3314.015(D) states that “[t]he decision of the department to di sapprove an entity for sponsorship of a community school * * * may be appealed by the entity in
accordance with section 119.12 of the Revised Code.” {¶ 22} We said in Brookwood that the “crux of this case is the interplay between [former] R.C. 3314.015(B)(3) and 3314.015(D).” Brookwood at ¶ 9. And we ultimately concluded that the state board’s “final” decision under former R.C. 3314.015(B)(3) was appealable under R.C. 3314.015(D). Id . at ¶ 18, 20. Importantly, we did so because the statute itself (R.C. 3314.01 5) contained “a specific, statutory grant of jurisdiction” explicitly allowing for appeals from a decision disapproving an entity for sponsorship of a community school. Id . at ¶ 15.
For the Brookwood majority, “that ma[de] all the difference.” Id

. {¶ 23} Thus, the key to Brookwood , 127 Ohio St.3d 469, 2010-Ohio-5710, 940 N.E.2d 1256, was the existence of a specific statutory prov ision allowing for the appeal of the department o f education’s decision disapprovi ng an entity for sponsorship. In our case, there is no parallel provision sayin g that a state board decision ordering repayment of funds can be appealed. So if we follow Brookwood , it is clear that there is no right to appeal the state board’s decision. {¶ 24} In arguing that the state board ’s decision is appealable, both ECOT and the dissent rely heavily on the interplay between the gener al provision in R.C. 119.12(B), which allows for adminis trative appeals, and the pro vision in R.C. 3301.13, which provides that the dep artment of education is sub ject to R.C. Chapter 119. But tellingly, the Brookwood majority did not find R.C. 3301.13’s reference to R.C. Chapter 119 to be of s ignificance in reaching its decis ion that the department of educati on’s final decision was appealable. The m ajority there stated that R.C. 3301.13 merely provided “the general rule that the [d epartment of education and state board] ‘[i]n the exercise of any of [their] functions or powersS UPREME C OURT OF O HIO

10 * * * shall be subject to Chapter 119. of the Revised Code.’ ” (Second brackets and ellipsis added in Brookwood .) Brookwood at ¶ 6, quoting R.C. 3301.13. {¶ 25} The dissent claims that its preferred result is “consistent” wi th our
decision in Brookwood

. See dissenting opinion at ¶ 55. Hardly so. The dissent
would hold that the state boa rd’s decision under R.C. 3314.08(K ) is appealable because of R.C. 3301.13, a notion implicitly rejected by the Brookwood court. This
construction renders i nconsequential the very provision that th e Brookwood court found made “all the difference.” Id. at ¶ 15. Our reading of the statute also finds support in a line of precedent from the Tenth District Court of Appeals—the court with the statutory directive to handle most administrative appe als, see R.C. 119.12(B)—holding that a statute’s characterization of an admin istrative body’s determination as “final” precl udes an R.C. Chapter 119 appeal. See, e.g. , Carney v. School Emps. Retirement Sys. Bd. , 39 Ohio App.3d 71, 72, 528 N.E.2d 1322 (10th Dist.1987) (the School Empl oyees Retirement System’s “fin al” decision on a person’s entitlement to disability retirement benefits may not be appealed); State ex rel. Shumway v. State Teachers Retirement Bd. , 114 Ohio App.3d 280, 284, 683 N.E.2d 70 (10th Dist.1996), fn. 1 (the Ohio State Teachers Reti rement System Board’s “final” determination as to retirement compensation cal culations is nonappealable); Heartland Jockey Club, Ltd. v. Ohio State Racing Comm. , 10th Dist. Franklin No. 98AP-1465, 1999 WL 566857, *1 (Aug. 3, 1999) (the State Racing
Commission’s “final” decision re garding horse-race simulcasting under R.C. 3769.089(E)(3) forecloses an appeal). Notably, this line of pr ecedent is rooted in cases predating the enactment of the enrollment-review statute in 1997. See Am.Sub.H.B. No. 215, Ohio Laws, Vol. 147, Part I, 909, 1194. I t is fair to presume that the legislature enacted the enrollment-review statute with knowledge of the judicial construction that had been afforded to administrative decisions statutorily designated as “final.” See Saccucci v. State Farm Mut. Auto. Ins. Co. , 32 Ohio St.3d 273, 276, 512 N.E.2d 1160 (1987) (sta ting that the legisl ature is presumed toJanuary Term, 2021

11 know when words have been judicially defined and, when it uses that word, it is presumed to have used it in t he sense so defined), citing Tax Comm. of Ohio v. Sec.
Savs. Bank & Trust Co. , 117 Ohio St. 443, 450, 159 N.E. 570 (1927). {¶ 26} Moreover, in Brookwood , this court cited that line of authority without any suggestion that thos e cases were wrongly decided. 127 Ohio St.3d 469, 2010-Ohio-5710, 940 N.E.2d 1256, at ¶ 14. To the contrary , Brookwood found these cases distinguishable because of the existence in f ormer 3314.015(B)(3) of “a specific, statutory grant of jurisdiction” to review a decision disapproving an entity for sponsorship of a community school. Brookwood at ¶ 15.
No such distinction ca n be made in our case.
IV. Conclusion {¶ 27} When read in context of the entire statute, it is clear that “f inal” is used in its ordinary sense, mar king the end of the enrollment-r eview statute’s twostep review process. Accordingl y, we hold that the state board ’s final determination that ECOT must repay some $60 million in excess funding cannot be appealed under R.C. Chapter 119. Judgment affirmed.
O’C ONNOR , C.J., and F ISCHER and G WIN , JJ., concur.
K ENNEDY , J., dissents, with an opinion joined by D ONNELLY and
S TEWART , JJ.
W. S COTT G WIN , J., of the Fifth District Court of Appeals, sitting for
B RUNNER , J.

_________________ K ENNEDY , J., dissenting. {¶ 28} Because the established legal meaning of the word “final” is th at the matter is concluded before a tribunal and subject to an appeal if one is otherwise provided by law, R.C. 3314.08(K)(2)(d) does not preclude appell ate review of appellee the Ohio State Board of Education’s (“the state board” ) “final”S UPREME C OURT OF O HIO

12 determination that a community s chool owes money to the state. Rather, R.C. 3301.13 and 119.12 create the right to an administrative appeal from all adjudications of the state board , including an adverse funding determination made pursuant to R.C. 3314.08(K). Therefore, I would reverse the ju dgment of the Tenth District Court of Appeals affirmi ng the dismissal of the admini strative appeal filed by appellant, the Electronic Cla ssroom of Tomorrow (“ECOT”). {¶ 29} R.C. 3314.08(K) establishes a procedure for appellee the Ohio Department of Education (“the de partment”) to review payments t o determine whether a community school has b een overpaid or underpaid. If the department determines that a community school has been overpaid, then the school may appeal
that determination to the state board. “Any decision made by t he [state] board under [R.C. 3314.08(K)] is final.” R.C. 3314.08(K)(2)(d). At issue in this case is whether the word “final” is synonym ous with “not appealable.” {¶ 30} Resolving this question returns us to a familiar place: statuto ry interpretation. As we explained long ago, “[t]he question is n ot what did the general assembly intend to enact, but wha t is the meaning of that which it did enact.” Slingluff v. Weaver , 66 Ohio St. 621, 64 N.E. 574 (1902), paragraph two of the syllabus. In conducting this task, “we must examine the statut ory scheme as a whole as well as the specific code sections immediately at issu e.” Holben v. Interstate Motor Freight Sys ., 31 Ohio St.3d 152, 156, 509 N.E.2d 938 (1987). “When the language of a statute is plain and unambiguous and co nveys a clear and definite meaning, there is no need for this court to apply the rules of statutory interpretation.” Symmes Twp. Bd. of Trustees v. Smyth , 87 Ohio St.3d 549, 553, 721 N.E.2d 1057 (2000). Rather, “[a]n unambiguous statute is t o be applied, not interpreted.” Sears v. Weimer , 143 Ohio St. 312, 55 N.E.2d 413 (1944), paragraph five of the syllabus. {¶ 31} R.C. 3301.13 creates the department , which consists of “the sta te board * * *, the superintendent o f public instruction, and a st aff of suchJanuary Term, 2021

13 professional, clerical, and othe r employees as may be necessary to perform the duties and to exercise the requi red functions of the department ,” id . That statute also provides that “[i]n the e xercise of any of its functions o r powers, including the power to make rules and regula tions and to prescribe minimum st andards the department * * *, and any officer or agency therein, shall be s ubject to Chapter 119.
of the Revised Code.” Id

. {¶ 32} With exceptions not relevant here, R.C. 119.12(B) states that “ [a]ny party adversely affected by any order of an agency issued pursu ant to any other adjudication may appeal to the c ourt of common pleas of Frankli n county.” R.C. 119.01(D) defines “adjudication” a s “the determination by the h ighest or ultimate authority of an agency of the ri ghts, duties, privileges, benef its, or legal relationships of a specified per son, but does not include the i ssuance of a license in response to an application with respect to which no question is raised, nor other acts
of a ministerial nature.” {¶ 33} We have long recognized that when R.C. 3301.13 and 119.12 are construed together, they create the right to an administrative appeal from an adjudication of the state board. Union Title Co. v. State Bd. of Edn ., 51 Ohio St.3d 189, 190-191, 555 N.E.2d 931 (1990). See also Rossford Exempted Village School Dist. v. State Bd. of Edn. , 45 Ohio St.3d 356, 362, 544 N.E.2d 651 (1989) (holding that an adjudication order of t he state board resulting from qu asi-judicial proceedings is “an appealable order pursuant to R.C. 119.12”), superseded by regulation as stated in Union Title Co. at 195; Smith v. Granville Twp. Bd. of
Trustees , 81 Ohio St.3d 608, 616, 693 N.E.2d 219 (1998) (“the act of th e State Board of Education disapproving a transfer of territory request pursuant to R.C. 3311.06 is a quasi-judicial act, a nd, as such, is appealable un der R.C. 119.12”); Bartchy v. State Bd. of Edn. , 120 Ohio St.3d 205, 2008-Ohio-4826, 897 N.E.2d 1096, ¶ 34 (lead opinion) (“A decision of the State Board of Ed ucation on an R.C. 3311.24 transfer request is app ealable under R.C. 119.12”).S UPREME C OURT OF O HIO

14 {¶ 34} In addition, R.C. 2505.03(A) provides that “when provided by la w, the final order of any administr ative officer, agency, board, d epartment, tribunal, commission, or other instrumentality may be reviewed on appeal by a court of common pleas, a court of appeals, or the supreme court, whichev er has jurisdiction.” R.C. 2505.03(B) state s that the procedures prov ided by Chapter 119
control in the case of an adminis trative appeal. Therefore, pu rsuant to R.C. 2505.03(A), the order of the state board must be final before i t is appealable. See Groveport-Madison Local Edn. Assn., O EA/NEA v. State Emp. Relations Bd. , 62 Ohio St.3d 501, 505, 584 N.E.2d 700 (1992); Hamilton Cty. Bd. of Mental Retardation & Dev. Disabilities v. Professionals Guild of Ohio , 46 Ohio St.3d 147, 152-153, 545 N.E.2d 1260 (1989) (lead opinion); id. at 155 (Brown, J., concurring). {¶ 35} R.C. 3301.13 provides that the dep artment, which includes the s tate board, is subject to R.C. Chapter 119, and pursuant to R.C. 119 .12(B), any party may appeal from any order in which the state board made an adverse decision affecting the party’s rights, du ties, privileges, benefits, or legal relationships. Further, when provided by law, the final order of any board or department may be appealed to a court of com petent jurisdiction. R.C. 2505.03(A)

. {¶ 36} This court has noted that “ ‘ “[a]ny” means “one or some indiscriminately of w hatever kind.” ’ ” Weiss v. Pub. Util. Comm ., 90 Ohio St.3d 15, 17, 734 N.E.2d 775 (2000), quoting State ex rel. Purdy v. Clermont Cty. Bd. of
Elections , 77 Ohio St.3d 338, 340, 673 N.E.2d 1351 (1997), quoting Webster’s Third New International Dictionary 97 (1971). The word “any” is “inclusive,” The Way Internatl. v. Limbach , 50 Ohio St.3d 76, 80, 552 N.E.2d 908 (1990), and “is often used as meaning ‘all,’ ” Wachendorf v. Shaver , 149 Ohio St. 231, 240, 78 N.E.2d 370 (1948), or “every,” State v. Wells , 146 Ohio St. 131, 137, 64 N.E.2d 593 (1945). {¶ 37} Therefore, unless some other more specific provision creates an express exception to the statutory right to an administrative a ppeal afforded by R.C.January Term, 2021

15 119.12(B), all final adjudication orders of the state board are appealable to the Franklin County Common Pleas Court pursuant to R.C. 3301.13 and 119.12(B). {¶ 38} R.C. 3314.08(K)(1) allows the depar tment to conduct a review of a community school’s enrollment dat a on which the department base s the community school’s funding. Relevant here is R.C. 3314.08(K)(2), which s tates:

If the review results in a finding that additional funding is owed to the school, such payment shall be made within thirty da ys of the written notice. If the review results in a finding that the community school owes moneys to the state, the following procedure shall apply: (a) Within ten business days of the receipt of the notice of findings, the community school m ay appeal the department’s
determination to the sta te board * * * or its designee. (b) The [state] board or its designee shall conduct an informal hearing on the matter w ithin thirty days of receipt of such an appeal and shall issue a decision within fifteen days of the conclusion of the hearing. (c) If the [state] board has enlisted a designee to conduct the hearing, the designee shall certify its decision to the [state] board. The [state] board may accept the decision of the designee or ma y reject the decision of the des ignee and issue its own decision on the

matter. (d) Any decision made by the [state] board under this division is final.

(Emphasis added.) “If it is deci ded that the community school owes moneys to the state, the department shall deduct such amount from the school’ s future paymentsS UPREME C OURT OF O HIO

16 in accordance with guidelines issued by the superintendent of p ublic instruction.” R.C. 3314.08(K)(3). {¶ 39} The state board maintains that by making its decision “final” w ithout also providing that the order is “appealable,” R.C. 3314.08(K)( 2)(d) precludes an appeal by a community school fro m the state board’s adverse fun ding
determination. {¶ 40} The General Assembly has not pr ovided a specific definition of the word “final” for purposes of R.C. 3314.08(K)(2)(d); we therefor e must construe its meaning according to its common usage. See R.C. 1.42. However, “[w]ords and phrases that have acquired a technical or particular meaning, w hether by legislative definition or otherwise, shall be construed accordingly.” Id. {¶ 41} One definition of the adjective “f inal,” as the majority points out, is
“ ‘not to be altered or undone .’ ” Majority opinion at ¶ 14, q uoting Webster’s Third New International Dictionary 851 (1986). Under this definition, the state board’s funding determination w ould be final, unaltera ble, and therefor e not subject to any appeal. Not even the state boa rd appears to believe that its d ecision is unalterable, however, because it asserts that its adverse funding determinat ion may be challenged by ECOT (and therefor e altered) in a mandamus action . If the state board’s decision were truly unalte rable, then it could not be u ndone by a tribunal. {¶ 42} In any case, that is not the only definition of the word “final .” It has acquired a more particular meani ng in the law of “not requiring any further judicial action by the court that rendered judgment to determine the mat ter litigated; concluded. * * * Once an order, judgment, or decree is final, it may be appealed
on the merits.” Black’s Law Dictionary 747 (10th Ed.2014); accord Webster’s Third New International Dictionary at 851 (defining “final” as “ending a court action or proceeding leaving nothing further to be determined b y the court * * * but not precluding an appeal”). In contrast, Black’s Law Dictionary defines “final andJanuary Term, 2021

17 conclusive” as “[t]erminal and unappealable, except on grounds of procedural error, fraud, or mistake.” Black’s Law Dictionary at 747. {¶ 43} As these definitions demonstrate, a decision that is “final” in the legal sense puts an end to the litigation before a particular t ribunal but does not
mean that the decision is unalte rable on appeal. We pointed ou t in Brookwood Presbyterian Church v. Ohio Dept. of Edn. that “in our system of law, ‘final’ can mean the opposite of ‘not appealable.’ ” 127 Ohio St.3d 469, 2 010-Ohio-5710, 940 N.E.2d 1256, ¶ 12. {¶ 44} This understanding that a tribunal’ s order may be “final” yet nonetheless subject to an appeal is well established. As the l ate Justice Felix Frankfurter once noted, requiring finality as the test for appe alability is “an historic characteristic” of appellate procedure. Cobbledick v. United States , 309 U.S. 323, 324, 60 S.Ct. 540, 84 L.Ed. 783 (1940) . The requirement for fi nality existed in the common-law courts of England and was carried over into the fede ral Judiciary Act
of 1789. Id . at 324-325; McLish v. Roff , 141 U.S. 661, 665, 12 S.Ct. 118, 35 L.Ed. 893 (1891). This court also accep ted the common-law rule that a writ of error is
not available until the matter before the inferior court is fin al. State ex rel. Cook v. Ottinger , 43 Ohio St. 457, 461, 3 N.E. 298 (1885); Kinsley v. State , 3 Ohio St. 508 (1854). The General Assembly extended the same rule to equitab le matters in 1830. Crick, The Final Judgment as a Basis for Appeal , 41 Yale L.J. 539, 549 (1932), quoting 29 Ohio Laws 90 (“appeals might be only from ‘any final sentence or decree made in any cause in chancery’ ”). And Ohio has retaine d finality as a requirement for appealability in Article IV, Section 3(B)(2) of the Ohio
Constitution and in statutes su ch as R.C. 2505.03, which establ ishes the general
rule that all final orders—fro m judicial and administrative bod ies alike—may be appealed to a court of c ompetent jurisdiction.S UPREME C OURT OF O HIO

18 {¶ 45} And the way that the General Assembly uses the word “final” in statutes addressing the appealability of final decisions confir ms that the word “final” in R.C. 3314.08(K)(2)(d) does not mean “unalterable” or “not appealable.” {¶ 46} In Title 33 alone, for example, the General Assembly states at various points that a decision is “final,” R.C. 3314.08(K)(2)(d ), 3365.12(B)(2); “final and not subject to app eal,” R.C. 3318.051(E); “final and is not appealable,” R.C. 3311.0510(A); “final and conclusive and not appealable,” R .C. 3345.76(A); and “final, except that the board of education of the school di strict affected by such a determination may appeal,” R.C. 3316.03(E). See also, e.g ., R.C. 2505.03(A) (final order may be appealed); R.C. 3770.13(B)(5) (“An order of the court made under division (B)(4) of this s ection is a final and appealable order”). The General Assembly’s use of different wor ds—i.e., “final” and “not appeal able”—signals that these words have different meanings. Obetz v. McClain , ___ Ohio St.3d ___, 2021- Ohio-1706, ___ N.E.3d ___, ¶ 21. Further, we are obligated to give effect to every
word in a statute and avoid a construction that would render an y provision superfluous. Rhodes v. New Philadelphia , 129 Ohio St.3d 304, 2011-Ohio-3279, 951 N.E.2d 782, ¶ 23. Construing the word “final” to mean “una lterable” or “not appealable” renders the words in the statutes me ntioned above ( and numerous other words or phrases in other statut es throughout the Revised Code) superfluous. {¶ 47} But the word “final” is not synonymous with “appealable,” eithe r. Instead, the word “final,” when used in the legal context of de scribing the effect of a tribunal’s decision, means that the matter is concluded in th at tribunal and subject to an appeal if one is otherwise provided by law. And because the General Assembly uses the word “final” consistently, a decision that is final may be appealable or not appealable, depending on the language of the relevant statute or statutory scheme either gran ting or denying an appeal. This co nstruction therefore does not render any language supe rfluous—the phrases “final and appealable” and “final and not appealable” may each be given effect. In contra st, construing theJanuary Term, 2021

19 word “final” as meaning “unalte rable” renders the statutory lan guage that an appeal is “final and appealable”—i.e., una lterable yet appealable—unin telligible. {¶ 48} The majority acknowledges that i n the legal context, finality generally corresponds with appeal ability, in the sense that an order that is final in one tribunal may be appealed to another. Majority opinion at ¶ 15. Nonetheless, in construing R.C. 3314.08(K)(2)(d), the majority would apply t he more literal usage of the word “final” to mean “unalterable” based upon the simple logic that because R.C. 3314.08(K)(2)(a) expressly permits an appeal from the department to the state board and because R.C. 3314.08(K)(2)(d) is silent on whether the final decision of the state board may be appealed, “final” must denot e “unalterable.” So, at its core, the majority’s reas oning turns on applying a versi on of the interpretive canon expressio unius est exclusi o alterius—which means that th e expression of one or more items of a class implies that those not identified are to be excluded, see State v. Droste , 83 Ohio St.3d 36, 39, 697 N.E.2d 620 (1998). {¶ 49} That analysis, however, depends on reading R.C. 3314.08(K)(2) i n isolation and ignoring the statut ory scheme that expressly prov ides for administrative appeals in general and appeals from the state bo ard in particular. But as the late Justice Antonin Scalia has cautioned, “Statutory co nstruction * * * is a holistic endeavor. A provision that may seem ambiguous in isol ation is often clarified by the remainder of the s tatutory scheme—because the same terminology is used elsewhere in a context that makes its meaning clear * * * or because only one of the permissible meanings produces a substantive effect t hat is compatible
with the rest of the law.” United Savs. Assn. of Texas v. Timbers of Inwood Forest Assocs., Ltd. , 484 U.S. 365, 371, 108 S.Ct. 626, 98 L.Ed.2d 740 (1988). {¶ 50} That is the case here. In statutes expressing the effect of a final decision, the General Assembly—throughout the Revised Code and within R.C.
Title 33—has used the word “final” in accordance with its estab lished legal meaning: the matter is conclude d before the tribunal and may—or may not—beS UPREME C OURT OF O HIO

20 subject to appeal to another tribunal. The majority’s grammati cal argument is therefore unpersuasive, since it fails to account for the fact that there is no difference in the structure of a sentence saying that an order is “final,” “final and appealable,” and “final and not appealable.” See majority opinion at ¶ 19. {¶ 51} And because the majority reads R.C. 3314.08(K)(2) in a vacuum a nd out of context, it misses a key difference between R.C. 3314.08 (K)(2)(a) and 3314.08(K)(2)(d). The General Assembly had not created a gener al right to appeal from a decision that has been made by the department to the sta te board, so R.C. 3314.08(K)(2)(a) is necessary to establish that right of review . In contrast, the General Assembly has provided a generally available right to ap peal from the final adjudication orders of the state board, R.C. 3301.13, 119.12(B) , and 2505.03(A), and it did not need to add langua ge to R.C. 3314.08(K)(2)(d) to trigger the right to appeal an adverse funding dete rmination. R.C. 3314.08(K)(2)(a) is not similar enough to R.C. 3314.08(K)(2)(d) for this court to draw an infer ence from the inclusion of right-to-appeal l anguage in R.C. 3314.08(K)(2)(a) that the General Assembly must have meant to deny a right to appeal from the sta te board’s adverse funding determination i n R.C. 3314.08(K)(2)(d). {¶ 52} “[T]his court has long recogni zed that the canon ‘expressio uni us est exclusio alterius’ is not an interpretive singularity but merel y an aid to statutory construction, which must yield w henever a contrary legislative intent is apparent.” Baltimore Ravens, Inc. v. Self-Insuring Emp. Evaluation Bd ., 94 Ohio St.3d 449, 455, 764 N.E.2d 418 (2002). There is a well-established meanin g of “final” in this context, which the General Assembly consistently uses in statut es relating to administrative appeals. The General Assembly also consistently uses express language when creating an excepti on to an otherwise-available a ppeal. After all, “expression unius est exclusio alterius is a double-edged sword.” Setser v. United
States , 566 U.S. 231, 238, 132 S.Ct. 1463, 182 L.Ed.2d 455 (2012). A nd while R.C. 3314.08(K)(2)(d) does not state that an adverse funding de termination isJanuary Term, 2021

21 “appealable,” it also does not i nclude language that the state board’s decision is “not appealable.” The focus of R.C. 3314.08(K)(2)(d) is finali ty—other provisions in the Revised Code address appealability. {¶ 53} For these reasons, the negative inference drawn by the majority has too little heft to demonstrate that the General Assembly must have meant to except an adverse funding determination by implication from the expres s right to appeal
from the state board’s fin al adjudication orders. See United States v. Vonn , 535 U.S. 55, 65, 122 S.Ct. 1043, 152 L.Ed.2d 90 (2002), quoting Burns v. United States , 501 U.S. 129, 136, 111 S.Ct. 2182, 115 L.Ed.2d 123 (1991) (“ ‘A n inference drawn from congressional silence certai nly cannot be credited when it is contrary to all
other textual and contextual evi dence of congre ssional intent’ ”). {¶ 54} Rather, the General Assembly enacted statutes providing that al l the state board’s final adjudication orders are appealable, and the state board’s adverse funding determination is an ad judication order that R.C. 3314.0 8(K)(2)(d) expressly makes “final.” In the absence of more specific langu age to the contrary denying an appeal—and there is none here—the state board’s orde r in this case is appealable. {¶ 55} This conclusion is consistent with our decision in Brookwood Presbyterian Church , 127 Ohio St.3d 469, 2010-Ohio-5710, 940 N.E.2d 1256. At issue in that case was R.C. 3314.015(D), which grants the right to an R.C. 119.12 appeal to any entity disapproved for sponsorship of a community school. A separate provision in that st atute, R.C. 3314.015(B)(3), provid es that the department’s determination that the entity was not education-or iented “is final.” We rejected the view that by using the word “final,” the Genera l Assembly intended to limit an entity’s right to appeal under R.C. 3314.015(D) and 119.12. Rather, we explained that “[h]ad the Genera l Assembly intended that the de partment’s determination of whether an entity is education-oriented not be subject to administrative appeal, it could have done so by appropriate lan guage, i.e., byS UPREME C OURT OF O HIO

22 specifying that the department’s decision is final and not subj ect to appeal.” Brookwood Presbyterian Church at ¶ 13. We continued: “[B]y calling that
determination ‘final’ but not calling it ‘not subject to appeal ,’ the General Assembly has concluded that that judgmen t is susceptible of review pursu ant to R.C. 119.12.”
Id. at ¶ 16. Therefore, the court declined to draw a negative infe rence from the
statute’s failure to s tate that the deter mination was both “fin al and appealable.” {¶ 56} Brookwood Presbyterian Church also distinguished decisions from lower appellate courts’ holdings that a statute’s characterizat ion of an administrative body’s decision as “f inal” precludes review thro ugh an R.C. 119.12 appeal, pointing out that none o f those cases involved “a speci fic, statutory grant of jurisdiction to the trial court to review the decisions of the administrative body pursuant to R.C. 119.12.” Id . at ¶ 15. But more importan tly, those appellate court cases cited by Brookwood Presbyterian Church had not held that the use of the word “final” created an exception to an otherwise available rig ht to appeal. Although the statute at issue in Brookwood Presbyterian Church involved the use of the word “final” in the same statute creating the right to a Chapter 119 appeal, for the reasons stated above, it is a distinction without a dif ference. {¶ 57} Because R.C. 3314.08(K)(2)(d) does not expressly limit the righ t of appeal afforded by R.C. 119.12(B) and 2505.03(A), the Franklin County Common Pleas Court has subject-matter jurisdiction to review a communi ty school’s administrative appeal taken from a final order issued by the st ate board pursuant to R.C. 3314.08(K). {¶ 58} Here, the state board issued a final order directing ECOT to re pay $60,350,791 that it had received over the 2015-2016 school year and directing the department to collect the overpay ment. ECOT had the right to p ursue an administrative appeal as provided by R.C. 119.12. The court of appeals erred in upholding the dismissal of ECOT’s appeal for lack of subject-ma tter jurisdiction.January Term, 2021

23 {¶ 59} The majority’s contrary conclusion results in this court’s deny ing ECOT any opportunity to challenge the state board’s order clawi ng back tens of millions of dollars. We granted the state board’s motion to di smiss ECOT’s mandamus action, in whic h it asserted that ECOT had an adequate remedy by way of this administrative appeal. See State ex rel. Electronic Classroom of Tomorrow v. State Bd. of Edn ., 150 Ohio St.3d 1426, 2017-Ohio-7567, 81 N.E.3d 1268. And today, the majority holds that ECOT has no right to an administ rative appeal, recognizing that a mandamus acti on will lie to challenge the st ate board’s adverse funding determinations in the future. Majority opinion at ¶ 7, fn. 2. But that
revelation comes too late for ECOT. {¶ 60} For these reasons, I would reverse the judgment of the Tenth Di strict Court of Appeals and remand this matter to the Franklin County Common Pleas Court to hear ECOT’s appeal. B ecause the majority does not, I dissent.
D ONNELLY and S TEWART , JJ., concur in the foregoing opinion.

_________________ Zeiger, Tigges & Little, L.L.P., Marion H. Little Jr., and Chr istopher J. Hogan, for appellant. Organ Law, L.L.P., and Eri k J. Clark, for appellees.

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