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Federal Home Loan Mortg. Corp. v. Schwartzwald, 2012 -Ohio- 5017.  The Ohio Constitution provides in Article IV, Section 4(B): “The courts of common pleas and divisions thereof shall have such original jurisdiction over all justiciable matters and such powers of review of proceedings of administrative officers and agencies as may be provided by law”. Reasoning that standing/subject matter jurisdiction must be determined at the time a suit is commenced, the court holds that a plaintiff without an interest in a note or mortgage at the time it filed a foreclosure action did not cure the lack of standing by subsequently obtaining an interest in the subject of the litigation.

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