Justia Ohio Supreme Court Opinion Summaries

In 2011, Appellee submitted a disability-retirement application to the Ohio Public Employees Retirement System and its board of trustees (together, “the Board”). The Board rejected Appellee’s claim for benefits. The Board also rejected Appellee’s appeal, finding that she was not permanently disabled. Appellee then filed suit for a writ of mandamus. The Court of Appeals granted the writ and ordered the Board to award benefits. The Supreme Court reversed, holding that the Court of Appeals abused its discretion by independently reevaluating the medical evidence and substituting its judgment regarding weight and credibility for that of the Board. View "State ex rel. Woodman v. Ohio Pub. Employees Ret. Sys." on Justia Law

Appellant was injured in the course and scope of his employment with the City of Columbus, Division of Fire. The Ohio Police & Fire Pension Fund granted Appellant’s application for a partial-disability retirement. Appellant subsequently accepted a position as a deer herd manager with Crosswoods Whitetails, LLC. Appellant applied to the Bureau of Workers’ Compensation for wage-loss compensation to partially compensate him for the difference between his average weekly wage as a firefighter and his lower earnings from Crosswoods. A hearing officer with the Industrial Commission denied Appellant’s application. Appellant filed this action in the court of appeals seeking a writ of mandamus. The court of appeals denied the writ. The Supreme Court affirmed, holding that the evidence demonstrated that Appellant failed to make “consistent, sincere, and best attempts to obtain suitable employment” that would eliminate the wage loss, and therefore, the Commission did not abuse its discretion in denying Appellant’s request for wage-loss compensation. View "State ex rel. Oldaker v. Indus. Comm’n" on Justia Law

In 2003, Appellee was injured while working for Appellant. In 2011, Appellee applied for permanent-total-disability compensation and submitted a report from his treating physician, Dr. Oscar DePaz. A hearing officer relied in part on the report of Dr. DePaz as support for the decision to award Appellee permanent-total-disability compensation. Appellant filed a complaint for a writ of mandamus alleging that the Industrial Commission had abused its discretion when it ordered compensation to begin on the date of Dr. DePaz’s report and claiming that Dr. DePaz’s report did not find that Appellee’s disability was solely the result of his medical impairment. The court of appeals denied Appellant’s request for a writ of mandamus. The Supreme Court affirmed, holding that the Commission did not abuse its discretion by (1) relying on the date of the DePaz report as the date on which to begin paying the award; and (2) determining that, based on the entire report, the DePaz opinion was evidence of permanent total disability based on the medical factors alone, thereby eliminating the need for further consideration of the nonmedical disability factors. View "State ex rel. Tradesmen Int’l v. Indus. Comm’n" on Justia Law

The State Teachers Retirement Board (STRB) denied the application of Jason Menz, an elementary school principal, for disability-retirement benefits on the grounds that Menz did not meet the criteria for permanent disability. Menz subsequently filed an action in mandamus in the court of appeals. The court of appeals granted a writ, concluding that STRB had abused its discretion in denying Menz disability benefits because both the treating physician and the independent physician had acknowledged that Menz had a condition that would prevent his return to work for at least one year. The Supreme Court affirmed, holding that Menz met the statutory criterion for an award of disability-retirement benefits under the relevant statute. View "State ex rel. Menz v. State Teachers Ret. Bd." on Justia Law

Appellant was injured in 2003 while working for Appellee. In 2010, Appellant applied for permanent total disability compensation. Kiva Shtull, M.D. examined Appellant on behalf of the employer and concluded that Appellant was capable of full-time employment. Craig Johnson, Ph.D., performed a vocational assessment and concluded that Appellant was capable of sedentary physical activity. A staff hearing officer denied Appellant’s application, determining that Appellant was vocationally capable of returning to work or going into a rehabilitation program. Appellant filed a complaint for a writ of mandamus, arguing that the staff hearing officer abused his discretion by relying on the reports of Shtull and Johnson. The court of appeals denied the writ. The Supreme Court affirmed, holding that there was evidence in the record to support the Commission’s denial of permanent-total-disability compensation. View "State ex rel. Lacroix v. Indus. Comm’n" on Justia Law

The Bureau of Workers’ Compensation conducted an adult of WFAL Construction and determined that WFAL owned back premiums as an “employer” subject to the Workers’ Compensation Act because those working for WFAL in 2009 were employees, not independent contractors as WFAL claimed. WFAL protested the audit findings. An adjudicating committee of the Bureau denied the protest, and the administrator’s designee affirmed. WFAL then filed this action for mandamus relief. The court of appeals concluded that the Bureau appropriately found that WFAL met the statutory criteria to support its decision that WFAL’s workers were employees. The Supreme Court affirmed, holding that WFAL failed to demonstrate that the Bureau’s decision was an abuse of discretion. View "State ex rel. WFAL Constr. v. Buehrer" on Justia Law

Claimant was injured when he fell while trying to cut a tree branch. Claimant filed an application for workers’ compensation benefits alleging that the injury had occurred while he was an employee of Appellee. The Bureau of Workers’ Compensation allowed the claim. Appellee purportedly appealed from the order of the Bureau, claiming that Claimant was not his employee at the time of the accident. The Commission concluded that Appellee’s appeal substantially complied with the statutory requirements for an administrative notice of appeal, accepted the appeal as valid, and referred the matter to a district hearing officer. A hearing officer disallowed the claim on the merits, concluding that Claimant was not an employee of Appellee. The Commission affirmed. Claimant filed a complaint for writ of mandamus alleging that the Commission abused its discretion in determining that Appellee’s administrative appeal was valid. The court of appeals denied the writ. The Supreme Court affirmed, holding that because Claimant had an adequate remedy at law by way of an appeal under Ohio Rev. Code 4123.512 regarding the issues he raised in this case, he was not entitled to relief in mandamus. View "State ex rel. Alhamarshah v. Indus. Comm’n" on Justia Law

Claimant was injured at work and later applied for permanent-total-disability benefits. The Industrial Commission denied the application. Claimant later filed a second application supported a letter from his treating physician, Dr. Karl Metz. The Commission also submitted a report from Dr. Steven Van Auken. A staff hearing officer denied permanent total disability based on the two reports. Claimant filed a complaint for a writ of mandamus alleging that the Commission abused its discretion because it failed to consider additional restrictions placed on him in the two reports. A magistrate concluded that the Commission did not abuse its discretion by relying on the reports of Drs. Metz and Van Auken. The court of appeals adopted the magistrate’s conclusions of law regarding Van Auken’s opinion but issued a limited writ of mandamus ordering the Commission to clarify Dr. Metz’s opinion or to obtain additional medical evidence. The Supreme Court reversed, holding that the court of appeals abused its discretion in granting the limited writ because its decision was based on speculation that there was a possible conflict in Dr. Metz’s report that could be construed to bar sedentary employment, which did not, by itself, justify the issuance of a limited writ. View "State ex rel. Metz v. GTC, Inc." on Justia Law

Sophia Stevens slipped and fell at work in 1979. Thirty years later, Stevens filed a motion for permanent-total-disability compensation. Through a staff hearing officer, the Industrial Commission initially granted benefits, but the full Commission later reconsidered the staff hearing officer’s order and denied Stevens’s request. Stevens filed a complaint for a writ of mandamus alleging that the Commission abused its discretion when it exercised continuing jurisdiction and denied compensation. The court of appeals (1) concluded that Stevens had not met her burden of proof for mandamus relief on the question of continuing jurisdiction, but (2) determined that Stevens was deprived of due process when one of the three voting commissioners did not attend the hearing. Thus the court issued a writ of mandamus ordering the commission to conduct another hearing with all three commissioners present. The Supreme Court reversed and denied the writ, holding (1) Stevens I properly focused on Stevens’s burden of proof for mandamus relief; (2) this Court’s decision in State ex rel. Sigler v. Lubrizol Corp. requires reversal of the judgment in Stevens II; and (3) the Commission’s order denying permanent-total-disability benefits is supported by the evidence. View "State ex rel. Stevens v. Indus. Comm’n" on Justia Law

Appellee filed a workers’ compensation claim from a work-related injury that occurred in 2007 while he was employed as a bricklayer for Appellant. Appellee had three other workers’ compensation claims from work-related injuries that occurred in 1992 and 2005. His claim was allowed. Appellee later applied for permanent-total-disability compensation. Appellee’s treating physician and a psychologist opined that Appellee was incapable of working due to his psychological condition caused by the 2007 injury. A staff hearing officer with the Industrial Commission granted Appellee’s application and ordered permanent total disability compensation. The hearing officer apportioned the cost of the award entirely to the 2007 claim. Appellant filed a complaint for a writ of mandamus. The court of appeals denied the writ, holding that Commission did not err by allocating the entire award to the 2007 claim. The Supreme Court affirmed, holding that the Commission did not abuse its discretion when it attributed the entire award to the 2007 claim. View "State ex rel. Turner Constr. Co. v. Indus. Comm’n" on Justia Law