Brookwood Presbyterian Church submitted an application to the Ohio Department of Education requesting approval as a sponsor of community schools in Ohio pursuant to R.C. 3314.02(C)(1)(f), which allows “education-oriented,” tax-exempt entities under Section 501(c)(3) of the Internal Revenue Code to sponsor community schools. The DOE subsequently determined Brookwood was not an “education-oriented” entity as required by R.C. 3314.02(C)(1)(f) and denied Brookwood eligibility to sponsor community schools. After much litigation, the Court of Appeals affirmed.