Land use and zoning attorney John P. Slagter reports that on March 28, 2006, the Ohio Supreme Court determined in the case of Bakies v. Perrysburg (2006), 108 Ohio St.3d. 361, that a municipality has no duty to continue to supply water to extraterritorial customers (customers outside of the city). The Court also held that it was legal for the City to require annexation to the City as a condition to either begin or continue the supply of City services. The Court found that requiring extraterritorial customers to agree to annexation in exchange for continuation of services is a valid exercise of police power and bears a rational relationship to the health, safety and welfare of the municipality’s citizens.