Justia Ohio Supreme Court Opinion Summaries

Articles Posted in Government & Administrative Law
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The Supreme Court reversed the judgment of the court of appeal denying Appellant's petition for a writ of mandamus and granted a limited writ of mandamus ordering the Industrial Commission to vacate its order denying Appellant's request for temporary total disability (TTD) compensation, holding that the order did not comply with State ex rel. Noll v. Industrial Commission, 567 N.E.2d 245 (Ohio 1991).The Commission denied Appellant's TTD compensation request because it found that Appellant had violated his employer's drug-free-workplace policy, thereby voluntarily abandoning his employment. Appellant sought a writ of mandamus ordering the Commission to conduct a new hearing, asserting that the Commission's order failed to set forth the evidence that the Commission relied on to conclude that his failed drug test was the reason for his termination. The Supreme Court granted a limited writ, holding that the order was deficient because it did not specifically state what evidence the hearing officer relied upon to conclude that Appellant was terminated for violating his employer's drug-free workplace policy, thereby voluntarily abandoning his employment. View "State ex rel. Merritt v. Industrial Commission" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus ordering the Ohio Department of Commerce, Division of Real Estate and Professional Licensing to convene an informal mediation meeting on a complaint, holding that Appellant had no clear legal right to a mediation meeting.A third party filed a complaint with the Division against Appellant, alleging that Appellant had falsified information on a mortgage application. The Division notified Appellant that he was the subject of the complaint. Appellant sent a letter containing a mediation request, but the Division failed to schedule a mediation meeting. Appellant then filed a complaint in the court of appeals seeking a writ of mandamus to compel the Division to schedule the meeting. The court of appeals denied the writ. The Supreme Court affirmed, holding that Appellant had no clear legal right to a mediation meeting, and the Division had no clear duty to hold one because Appellant's letter was incontestably untimely. View "State ex rel. Figueroa v. Ohio Department of Commerce, Division of Real Estate & Professional Licensing" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus ordering the Industrial Commission to grant Appellant's request for permanent-total-disability (PTD) compensation, holding that the court of appeals correctly denied the writ.The Commission found that Appellant had voluntarily abandoned the workforce and denied his request for PTD compensation. Appellant asked the court of appeals for a writ of mandamus ordering the Commission to vacate its decision and grant his application for PTD compensation. The Commission denied the writ, concluding that the Commission did not abuse its discretion. The Supreme Court affirmed, holding that the Commission's decision that Appellant voluntarily abandoned the workforce was supported by some evidence in the record. View "State ex rel. Bonnlander v. Hamon" on Justia Law

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The Supreme Court denied Petitioner's request for a writ of mandamus arguing that he was entitled to unredacted copies of the Southern Ohio Correctional Facility's most recent shift-assignment duty rosters, holding that the documents fell under the security-records exemption to the Public Records Act.Petitioner, an inmate, requested copies of documents that detailed the assignment of prison guards to various posts within the prison. Larry Greene, the prison's public-records custodian, turned over the records but redacted the majority of the information. Petitioner requested a writ of mandamus. The Supreme Court denied the writ, holding (1) because the documents were security records, they were exempt from disclosure under the Public Records Act, and Greene had no legal duty to turn them over; and (2) none of the exemptions to the Public Records Act applied. View "McDougald v. Greene" on Justia Law

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The Supreme Court denied the writs of mandamus sought by Relators, Marie Nauth and the group Concerned Citizens of Medina City (CCMC), seeking an order directing members of the Medina County Board of Elections (collectively, the Board) to certify as valid forty-seven signatures that Relators say the Board invalidated as not genuine, holding that Relators did not meet their burden to show an abuse of discretion by the Board.Relators filed a referendum petition that fell forty-four signatures short of qualifying for the November 3, 2020 general election ballot. Relators then commenced this action seeking a writ of mandamus that would direct the Board to reexamine the signatures on the referendum petition and certify as valid the signatures of qualified electors that they signed the referendum petition. The Supreme Court denied the writs, holding that Relators failed to prove by clear and convincing evidence that the forty-seven signatures at issue were invalidated in the first place and for what reasons. View "State ex rel. Nauth v. Dirham" on Justia Law

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The Supreme Court denied a writ of prohibition to prevent the three members of a board of county commissioners from going forward with a show-cause hearing to consider the removal of a member of the board of trustees of the county hospital, holding that the commissioners did not patently and unambiguously lack jurisdiction to proceed with the show-cause hearing.The Morrow County Board of Commissioners claimed that the authority to appoint and remove members of the Morrow County Hospital Board of Trustees was a five-member body, with each commissioner having one vote. Patrick Drouhard, the chairman of the Board of Trustees, claimed that the appointing authority was a three-member body, with the board of commissioners having a single collective vote and the other votes belonging to the judges of the Morrow County Court of Common Pleas. When the Commissioners sought to schedule a show-cause hearing to remove Drouhard as chairman of the Hospital Board Drouhard filed this complaint for a writ of prohibition. The Supreme Court denied the writ, holding (1) the three commissioners constitute the majority of the appointing authority that is empowered by law to remove a member of the county hospital board; and (2) Drouhard possessed an adequate remedy by way of an appeal following the show-cause hearing. View "State ex rel. Drouhard v. Morrow County Board of Commissioners" on Justia Law

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The Supreme Court denied the writ of mandamus sought by Relators compelling Tuscarawas County Job and Family Services (TCJFS) to produce copies of, or permit Relators to inspect, records pertaining to their childhood history with TCJFS, holding that TCJFS did not have a clear legal duty to allow Relators to inspect or copy the records they sought.Relators were sisters who spent portions of their childhoods in the Tuscarawas County foster care system. Relators believed that they experienced trauma while in foster care and that access to their TCJFS records would help them move forward with their lives. Relators commenced this mandamus action seeking to compel TCJFS to produce copies of, or permit Relators' access to, TCJFS records pertaining to them. The Supreme Court denied the writ, holding (1) the TCJFS director's good-cause finding did not create a legal duty requiring TCJFS to give Relators full access to all TCJFS records pertaining to them; (2) Ohio.Adm.Code 5101:2-33-21(H) did not impose a duty on TCJFS to disseminate any records to Relators; and (3) Relators failed to submit sufficient evidence supporting that there was good cause to override Ohio Rev. Code 5153.17's confidentiality requirement. View "State ex rel. Martin v. Tuscarawas County Job & Family Services" on Justia Law

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The Supreme Court denied the writ of mandamus sought by a judge seeking to compel a county to pay for his outside legal counsel, holding that the judge was not entitled to compel the county to pay for his lawyer.In 2018, Greene County Probate Judge Thomas O'Diam issued two orders that sought to take control of a courtroom. The orders also sought to compel Greene County to pay for the legal expenses arising from the Greene County Board of Commissioners' failure to comply with the orders. After the Board filed a petition for a writ of prohibition attempting to stop Judge O'Diam's orders from taking effect Judge O'Diam filed the present mandamus action seeking to enforce his orders. The Supreme Court granted the writ of prohibition. At issue in this mandamus proceeding was whether Judge O'Diam was entitled to outside counsel at the County's expense when he did not use the process set forth in Ohio Rev. Code 309.09(A), 305.14(A), and 305.17. The Supreme Court denied the requested writ of mandamus, holding that Judge O'Diam did not follow the statutory process, and therefore, he was not entitled to have the County pay his attorney fees. View "State ex rel. O'Diam v. Greene County Board of Commissioners" on Justia Law

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In this class action, the Supreme Court reversed the judgment of the court of appeals affirming the common pleas court's decision to certify the class, holding that the common pleas court lacked subject matter jurisdiction over the class action for the named and prospective class plaintiffs whose claims for recovery fell within the express language of Ohio Rev. Code 5160.37.The class action sought a declaratory judgment that former Ohio Rev. Code 5101.58 relating to Medicaid reimbursements is unconstitutional. The action further sought to recover all sums paid to the Ohio Department of Medicaid (Department) under section 5101.58. Plaintiff moved to certify as a class all persons who paid any amount to the Department pursuant to the statute from April 6, 2007 to the present. The trial court certified the class. The court of appeals affirmed. The Supreme Court reversed, holding (1) section 5160.37 now provides the sole remedy for Medicaid program participants to recover excessive reimbursement payments made to the Department on or after September 29, 2007; and (2) therefore, the common pleas court lacked jurisdiction over the claims asserted by Plaintiffs. View "Pivonka v. Corcoran" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals granting the city of Xenia's request for a writ of mandamus ordering the Greene County Board of Commissioners (the county) to approve the city's annexation petition, holding that the city's petition satisfied the conditions of Ohio Rev. Code 709.23(E).The proposed annexation in this case concerned approximately forty-five acres of land located between Central State University and Xenia. The county denied the petition, determining that the petition did not satisfy section 709.023(E)(1), (4), (5), or (7). Thereafter, the city filed an original action in the court of appeals requesting a writ of mandamus compelling the county to approve the petition. The court of appeals issued the writ. The Supreme Court affirmed, holding (1) a writ of mandamus is a proper vehicle to compel the county to grant the petition; and (2) the city's petition satisfied the conditions specified in section 709.023(E). View "State ex rel. Xenia v. Greene County Board of Commissioners" on Justia Law