Justia Ohio Supreme Court Opinion Summaries

After the mayor of Streetsboro resigned, Arthur Scott was appointed to serve as acting mayor. Five months later, Scott was elected to serve for the remainder of the former mayor’s term. Following his reelection, Scott filed a petition for a writ of mandamus alleging that he was underpaid for his service as mayor and acting mayor and that he was entitled to compensation for unused vacation, sick, and personal leave. The court of appeals granted summary judgment in favor of Streetsboro. The Supreme Court affirmed in part and reversed in part, holding that the court of appeals (1) did not abuse its discretion in failing to grant Scott’s motion to strike several documents that Streetsboro attached to its response to Scott’s motion for summary judgment; (2) did not err in granting summary judgment to Streetsboro regarding Scott’s entitlement to additional pay for his service as acting mayor and as the elected mayor of the city; but (3) erred in granting summary judgment to Streetsboro as to Scott’s entitlement to compensation for unused vacation, sick, and personal leave. Remanded. View "State ex rel. Scott v. Streetsboro" on Justia Law

Attorneys employed by the Franklin County Public Defender sought membership and service credit in the Ohio Public Employees Retirement System for their years of service prior to January 1999, and challenged a decision the Ohio Public Employees Retirement Board’s denial of service credit. Persons hired by the Franklin County Public Defender on or before December 31, 1984, are public employees entitled to PERS benefits; effective January 1, 1999, the Franklin County Public Defender’s employees have been enrolled in and considered to be members of PERS. During the intervening years, pursuant to the Ohio Public Defender Act (R.C. Chapter 120), the Franklin County Public Defender Commission and its employees paid Social Security taxes on wages and did not consider the office to be a county agency. The Court of Appeals denied relief. The Supreme Court of Ohio granted a writ of mandamus to compel the board to award service credit, rejecting an argument that “there was no person holding the office of Franklin County Public Defender between 1985 and 1999 because a person was appointed as the ‘Director’ of the corporation. The plain language in R.C. 120.14(A)(1) indicates that the attorneys were employed by a public official, and hence, were public employees. View "Altman-Bates v. Pub. Emps. Retirement Bd." on Justia Law

Marcus Pryor applied to the Ohio Department of Job and Family Services (ODJFS) for unemployment compensation. The director of ODJFS concluded that Pryor was ineligible for benefits. A hearing officer with the Unemployment Compensation Review Commission affirmed. The Commission denied Pryor’s request to review the hearing officer’s findings. Pryor filed an appeal in the common pleas court naming the director of ODJFS as the appellee but failing to name the Army, Pryor’s former employer, as a party to his appeal. The common pleas court dismissed the appeal, finding that because Pryor failed to name the Army was an interested party, his notice of appeal did not comply with Ohio Rev. Code 4141.282(D), thus depriving the court of subject-matter jurisdiction. The court of appeals reversed the common pleas court’s dismissal of Pryor’s appeal and reinstated Pryor’s administrative appeal in the common pleas court, ruling that Pryor’s failure to name the Army was not a jurisdictional defect. The Supreme Court reversed, holding (1) the naming of interested parties is not a jurisdictional requirement under section 4141.282; but (2) the Commission failed to comply with the procedural requirements in section 4141.282(D), and therefore, Pryor’s time to appeal the Commission’s decision never started to run. Remanded. View "Pryor v. Dir., Ohio Dep’t of Job & Family Servs." on Justia Law

Daniel Stolz worked for a subcontractor on a construction project when he was injured in an accident on the job site. Prior to the accident, Messer had obtained authority from the Ohio Bureau of Workers’ Compensation to act as the self-insuring employer on the project, which gave Messer responsibility for providing workers’ compensation coverage for its own employees as well as the employees of enrolled subcontractors on the project. Stolz brought negligence claims against Messer Construction, the general contractor, and several subcontractors. A federal district court granted summary judgment to Messer as the self-insuring employer but denied summary judgment to the subcontractors, concluding that an enrolled subcontractor on a self-insured construction project is immune from claims made by its own employees but not from those made by employees of other enrolled subcontractors. The federal court then certified a question of state law to the Supreme Court. The Supreme Court answered that subcontractors enrolled in a self-insured construction project plan are immune from tort claims for workplace injuries from employees of other enrolled subcontractors on the same project. View "Stolz v. J & B Steel Erectors, Inc." on Justia Law

Robert Boyd retired from Scotts Miracle-Gro Company in 1983. Boyd received workers’ compensation benefits in 2005 for asbestosis in both lungs. In 2013, Boyd applied for permanent-total-disability benefits. A staff hearing officer at the Industrial Commission denied Boyd’s application. Boyd then filed a complaint seeking a writ of mandamus that would require the Commission to vacate its decision. The court of appeals denied the writ. The Supreme Court affirmed, holding that Boyd’s complaint in mandamus failed where Boyd failed to demonstrate that the Commission abused its discretion by entering an order not supported by any evidence in the record. View "State ex rel. Boyd v. Scotts Miracle-Gro Co." on Justia Law

Robert Boyd retired from Scotts Miracle-Gro Company in 1983. Boyd received workers’ compensation benefits in 2005 for asbestosis in both lungs. In 2013, Boyd applied for permanent-total-disability benefits. A staff hearing officer at the Industrial Commission denied Boyd’s application. Boyd then filed a complaint seeking a writ of mandamus that would require the Commission to vacate its decision. The court of appeals denied the writ. The Supreme Court affirmed, holding that Boyd’s complaint in mandamus failed where Boyd failed to demonstrate that the Commission abused its discretion by entering an order not supported by any evidence in the record. View "State ex rel. Boyd v. Scotts Miracle-Gro Co." on Justia Law

Appellees were employed as sales representatives by a company that was owned by Appellants. Appellants filed a class action lawsuit seeking a declaration that certain provisions of Ohio Rev. Code 4111.14 were unconstitutional and a declaration that, as employees, they were entitled to minimum wage. Specifically, Appellants argued (1) because Ohio Rev. Code 4111.14(B)(1) contains exemptions from the definition of “employee” that Ohio Constitution, Article II, Section 34a does not contain, the statute is unconstitutional; and (2) section 4111.14(B) does not apply to claims for minimum wage violations brought under the Constitution. The trial court declared that section 411.14(B)(1) is constitutionally valid and that the exemptions within the statute apply to claims brought under Article II, Section 34a. The Court of Appeals reversed, concluding that the General Assembly exceeded its authority when it defined “employee” differently, and more narrowly, than did the Constitution. The Supreme Court reversed, holding that section 4111.14(B)(1) is constitutional because its definition of the term “employee” does not clearly conflict with the definition of the same term set forth in Article II, Section 34a. View "Haight v. Minchak" on Justia Law

The Ohio Board of Nursing commenced a professional disciplinary action against Beverly Clayton, a staff nurse in the intensive care unit (ICU) of Mercy Hospital Western Hills, for alleged violations of Ohio Rev. Code 4723. In a number of separate motions, Clayton requested subpoenas for the personal appearance of numerous people and subpoenas duces tecum seeking to obtain several different collections of documents. The Board filed a motion to limit subpoena request, arguing that the number of requests was successive. The hearing examiner denied the Board’s motion in large part but granted the request with respect to certain ICU patient records. After a hearing, the hearing examiner concluded that discipline was warranted. The trial court affirmed the Board’s decision. The court of appeals affirmed, implying that the hearing examiner’s decision to limit the subpoena may have been erroneous but that Clayton failed to establish prejudice. The Supreme Court affirmed, holding (1) a hearing examiner for the Board of Nursing has the discretion to limit or quash subpoenas requested during disciplinary proceedings; and (2) the hearing examiner’s decision to limit Clayton’s subpoena duces tecum in this case was not an abuse of discretion. View "Clayton v. Ohio Bd. of Nursing" on Justia Law

Plaintiffs, former correctional institution employees and a labor union, filed this action against numerous government Defendants, alleging that 2011 Am.Sub.H.B. No. 153, the budget bill for the 2012-2013 biennium, violates the Ohio Constitution. H.B. 153 modified prior law governing contracts for the private operation and management of a state correctional institution in several ways. The court of common pleas granted Defendants’ motion to dismiss, concluding (1) the court lacked jurisdiction to determine whether employees of privately owned or operated prisons were employees, as defined by Ohio Rev. Code 4117.01(C); and (2) the court had jurisdiction over the constitutional challenges to H.B. 153, but Plaintiffs failed to state a claim that H.B. 153 was unconstitutional. The court of appeals reversed in part and ordered the trial court to hold an evidentiary hearing to determine whether H.B. 153 violates the one-subject rule in Ohio Const. art. II, 15(D). The Supreme Court affirmed in part and reversed in part, holding (1) H.B. 153 is constitutional; and (2) the State Employee Relations Board has exclusive jurisdiction to determine public-employee status under section 4117.01(C). View "State ex rel. Ohio Civil Serv. Employees Ass’n v. State" on Justia Law

Robert Mason was injured while working as a truck driver for Old Dominion Freight Line, Inc. Mason later applied for permanent-total-disability compensation. The Industrial Commission of Ohio granted Mason’s application based on the reports of two Commission specialists. Old Dominion filed a complaint for a writ of mandamus that would require the Commission to vacate its award of permanent-total-disability compensation, maintaining that the reports were flawed because the doctors did not review the defense medical reports in advance of their independent medical examinations. The court of appeals denied the writ. The Supreme Court affirmed, holding (1) Old Dominion’s request to depose the doctors was not reasonable; and (2) the reports constituted some evidence of permanent total disability, and therefore, Old Dominion failed to establish a clear legal right to the relief requested and a clear legal duty on the part of the Commission to provide such relief. View "State ex rel. Old Dominion Freight Line, Inc. v. Indus. Comm’n" on Justia Law