Justia Ohio Supreme Court Opinion Summaries

Dean Sziraki was seriously injured in the course of his employment and spent the next sixteen years as a quadriplegic. After Sziraki died in 2007, his estate filed a claim for death benefits. The Bureau of Workers' Compensation (Bureau) awarded compensation, but the benefits did not include accrued compensation for scheduled-loss benefits pursuant to Ohio Rev. Code 4123.57(B) for the loss of use of Sziraki's arms and legs. The Industrial Commission awarded compensation for the total loss of use of Sziraki's four extremities for 850 weeks. The Commission, however, limited the amount payable to period of two years, the amount Sziraki would have been entitled to had he filed for compensation on the date of his death, due to the two-year limit on retroactive payment under section 4123.57(B). The court of appeals denied the estate's writ of mandamus requesting an order that the Commission award the full 850 weeks. The Supreme Court affirmed, holding (1) the Commission did not abuse its discretion when it limited payment of the benefits to the two years preceding Sziraki's death; and (2) the court of appeals correctly concluded the Bureau had no duty to award the benefits during Sziraki's lifetime in the absence of an application. View "State ex rel. Estate of Sziraki v. Adm'r, Bureau of Workers'Â Comp." on Justia Law

Terry Sigler was employed by the Lubrizol Corporation when he was injured. A staff hearing officer with the Industrial Commission awarded Sigler permanent-total-disability compensation. Lubrizol filed a motion for reconsideration, which the Commission granted. Following a hearing, the Commission vacated the award. Sigler filed a complaint for a writ of mandamus in the court of appeals, contending that the Commission had abused its discretion in issuing the reconsideration order because one of the two commissioners voting to overturn had not attended the hearing but had relied on an oral summary of the evidence from a Commission hearing officer who had attended the hearing and taken handwritten notes. The court of appeals issued the writ of mandamus requiring the Commission to vacate its order, concluding that the Commission's hearing did not comport with the due process standards set forth in State ex rel. Ormet Corp. v. Indus. Comm'n. The Supreme Court reversed the court of appeals and denied the writ, holding that Sigler failed to demonstrate that the Commission's voting procedures violated due process. View "State ex rel. Sigler v. Lubrizol Corp." on Justia Law

Appellant was employed by Employer until December 2009. In 2009, Appellant authorized Employer to deposit $900 of her monthly earnings into a flexible-spending account for tax-free reimbursement of medical expenses. After Appellant was terminated from employment, she applied for unemployment compensation benefits. The Ohio Department of Jobs and Family Services (ODJFS) denied benefits, ruling (1) Appellant was required to have earned an average weekly wage of at least $213 for twenty qualifying weeks to be eligible for unemployment compensation, (2) the amounts that went into Appellant' flexible-spending account were not remuneration for purposes of determining her unemployment compensation eligibility, and (3) with the exclusion of those amounts, Appellant's average weekly wage was only $125. The Unemployment Compensation Review Commission affirmed. The court of common pleas and court of appeals affirmed. The Supreme Court affirmed, holding that the ODJFS's interpretation of the relevant statute was lawful and reasonable. View "Bernard v. Unemployment Comp. Review Comm'n" on Justia Law

Appellant was employed as a laborer by County Saw & Knife. Appellant successfully sought workers' compensation after he developed respiratory problems from his exposure to metal dust. One year later, Appellant applied for an additional award, alleging that Country Saw violated specific safety requirements (VSSRs). The Industrial Commission denied Appellant's application, concluding that County Saw had not violated the VSSRs. The court of appeals denied Appellant's request for a writ of mandamus that would require the Commission to vacate its order denying Appellant's application. The Supreme Court affirmed, holding that Appellant did not present sufficient evidence to establish that he was entitled to an award for a VSSR in addition to his extant workers' compensation benefits. View "State ex rel. Scott v. Indus. Comm'n" on Justia Law

Employee was injured while in the course and scope of his employment. Employee's industrial claim was allowed for certain injuries. Fourteen years later, Employee successfully requested compensation for the total loss of the functional use of his right arm. Based on the Industrial Commission's award for loss of use, one year later Employee filed a motion for compensation for statutory permanent total disability. A staff hearing officer denied the application. The court of appeals granted Employee's writ of mandamus, concluding that the loss of use of Employee's arm could not be relitigated and that the Commission was bound by the doctrine of collateral estoppel to issue the award. The Supreme Court reversed the judgment of the court of appeals and denied the writ of mandamus, holding (1) the Commission must conduct an independent evaluation of the facts when considering an application for statutory permanent disability under Ohio Rev. Code 4123.58(C) even if a prior award for the same body parts has been given pursuant to Ohio Rev. Code 4123.57(b); and (2) the evidence in the record supported the basis for the Commission's decision. View "State ex rel. Coleman v. Indus. Comm'n of Ohio" on Justia Law

Employee was involved in a motor-vehilce accident while operating a one-ton dump truck within the course of his employment by Employer. Employee applied for and received benefits for his physical injuries. Employee subsequently requested an additional allowance for posttraumatic-stress disorder (PTSD) that arose contemporaneously as a result of the accident. The Bureau of Workers' Compensation (BWC) allowed Employee's additional claim. The trial court held that Employee's PTSD was not compensable because it did not arise from his physical injuries. The court of appeals affirmed. The Supreme Court affirmed, holding (1) for a claimant's PTSD to qualify as a compensable injury under Ohio Rev. Code 4123.01(C)(1), the claimant must establish his PTSD was causally related to his compensable physical injuries and not simply to his involvement in the accident; and (2) the court of appeals appropriately determined that the record contained competent, credible evidence supporting the trial court's finding that Employee's physical injuries did not cause his PTSD and that Employee's PTSD was, therefore, not a compensable injury under section 4123.01(C)(1). View "Armstrong v. John R. Jurgensen Co. " on Justia Law

Appellants were five upper-level employees of the Ohio Department of Natural Resource's Division of Wildlife (DOW). The Ohio inspector general (OIG) asked a deputy inspector to investigate alleged misconduct of a DOW wildlife officer. The inspector interviewed Appellants. The OIG's subsequent investigative report concluded that Appellants failed to report the wildlife officer's criminal conduct to the appropriate authorities. A grand jury later indicted each appellant on obstructing justice and complicity in obstructing justice. Appellants filed motions to suppress or, alternatively, dismiss, on the ground that their statements to the investigator were coerced by threat of job loss and were therefore inadmissible under Garrity v. New Jersey. The trial court suppressed Appellants' statements as compelled and therefore inadmissible under Garrity. The court of appeals reversed. The Supreme Court reversed, holding Appellants' statements during the OIG investigation required suppression because Appellants answered questions after receiving a warning that they could be fired for failing to do so, and statements extracted under these circumstances cannot be considered voluntary within the meaning of Garrity. View "State v. Graham" on Justia Law

In 1990, Employee was working for Employer when she injured her left ankle. By 2009, Employee had multiple surgeries and was taking approximately fourteen medications. That same year, a Dr. Randolph concluded Employee required no further medical treatment for her 1990 industrial injury and other allowed conditions in her claim and that her current medications were no longer necessary. Employee subsequently filed a motion with the Industrial Commission for the loss of use of her left arm. Based on Dr. Randolph's addendum to his original report, a hearing officer denied Employee's motion for compensation for the loss of use of her arm. Employee filed a complaint for a writ of mandamus, which the court of appeals denied, concluding that Dr. Randolph's second and third reports, issued as addenda to his original report, constituted some evidence upon which the Commission could rely to support its decision denying Appellant's claim. The Supreme Court affirmed, holding that because the addenda of Dr. Randolph constituted some evidence to support the Commission's decision to deny Employee's request for compensation for the loss of use of her left arm, the Commission did not abuse its discretion, and the court of appeals properly denied the writ. View "State ex rel. Kish v. Kroger Co." on Justia Law

Relators in this case were instructors who were hired to instruct students in the Jefferson County's virtual learning academy (VLA), a cyber school for grades K-12. In 2008, the State Teachers Retirement Board of Ohio (STRS) determined that the VLA instructors were independent contractors instead of employees and refunded all contributions made by Jefferson County Educational Service Center Governing Board (Jefferson County ESC) on the VLA instructors' behalf. Relators sought writs of mandamus to compel the STRS to accept employer and employee contributions to its retirement fund and to compel the Jefferson County ESC to make employer contributions to the retirement system on their behalf. The court of appeals denied relief. The Supreme Court affirmed, holding that Relators failed to establish that the STRS abused its discretion in determining that they were not "teachers" within the meaning of Ohio Rev. Code 3307.01(B)(5) because the instructors were independent contractors, and not employees, of the Jefferson County ESC. View "State ex rel. Nese v. State Teachers Ret. Bd. of Ohio" on Justia Law

Appellant was injured during the course and scope of his employment. Appellant filed a motion for temporary total disability compensation, which a hearing officer granted. The Industrial Commission later terminated temporary total disability compensation based on the report of doctor who stated that the allowed conditions in Appellant's workers' compensation claim had reached maximum medical improvement. Appellant filed a complaint in mandamus, alleging that the Commission acted contrary to law when it relied on the report of the doctor. The court of appeals denied the writ, concluding that the doctor's report constituted some evidence upon which the Commission could rely. The Supreme Court affirmed, holding that the doctor's report was sufficiently reliable to constitute some evidence to support the Commission's decision. View "State ex rel. Coleman v. Schwartz" on Justia Law