Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the court of appeals affirming the trial court's judgment granting Plaintiff's motion to certify a class action, holding that when a class-certification case originates with a single named plaintiff and that plaintiff is not subject to an arbitration agreement that was entered into by unnamed putative class members, the defendant need not raise a specific argument referring or relating to arbitration in the defendant's answer.Plaintiff filed a class-action complaint against Defendant, his former employer. When Plaintiff moved to certify the case as a class action Defendant opposed the motion, asserting the defense of arbitration. The trial court granted the motion, concluding that Defendant waived any right of arbitration. The appellate court affirmed, determining that Defendant's failure to assert the arbitration defense in his answer or to seek to enforce the right to arbitration prior to its opposition to the certification was inconsistent with its right to assert the defense. The Supreme Court reversed, holding (1) because arbitration was not available as a defense at the time Defendant submitted its answer, Defendant could not waive a right to assert arbitration at that time; and (2) Defendant had no duty to raise an argument that Plaintiff failed to satisfy Civ.R. 23(A)'s typicality and adequacy requirements. View "Gembarski v. PartsSource, Inc." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that the Industrial Commission did not abuse its discretion when it found that Alfredo Pacheco was medically able to perform light-duty work offered by his employer, Aluminum Company of America (Alcoa) but reversed the conclusion that Alcoa did not make the light-duty job offer in good faith, holding that the court of appeals should not have determined whether the job was offered in good faith.Pacheco sustained an injury while working for Alcoa and received temporary total disability (TTD) compensation for approximately one year. Thereafter, Alcoa offered Pacheco light-duty employment. Pacheco accepted the offer and worked in the light-duty position for three weeks. Pacheco then submitted a renewed request for TTD compensation, which Alcoa denied. The Commission denied the request for TTD compensation based on a finding that the light-duty job was within Pacheco's medical restrictions. The court of appeals concluded that the evidence supported the Commission's finding but also concluded that the job offered by Alcoa was not offered in good faith. The Supreme Court reversed in part, holding that where the Commission did not address the question of whether the light-duty job offer was made in good faith, the court of appeals should not have made that determination. View "State ex rel. Pacheco v. Industrial Commission" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals ordering the Industrial Commission of Ohio to vacate its order denying the request of Joshua Pilarczyk for permanent total disability (PTD) compensation, holding that the court of appeals erred in relying on the report of Dr. Kenneth Gruenfeld in making its decision.Dr. Gruenfeld undertook an independent psychological evaluation of Pilarczyk at the request of the Bureau of Workers' Compensation and then issued a report stating that Pilarczyk was likely able to perform sustained remunerative employment despite his psychological disability. The Commission denied Pilarczyk's request for PTD compensation based in part on Dr. Gruenfeld's report. The court of appeals concluded that the Commission abused its discretion by denying PTD compensation based on Dr. Gruenfeld's report and issued a writ of mandamus ordering the Commission to vacate its order denying PTD compensation. The Supreme Court affirmed, holding that Dr. Gruenfeld's report was equivocal and ambiguous, and therefore, it did not constitute "some evidence" in support of the Commission's determination that Pilarczyk could engage in sustained remunerative employment. View "State ex rel. Pilarczyk v. Geauga County" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus against the warden of the Marion Correctional Institution, holding that Appellant's noncompliance with Ohio Rev. Code 2969.25(C) was a sufficient reason to dismiss the petition.The court of appeals dismissed the petition because Appellant, an inmate, had failed to submit an inmate-account statement, as required by section 2969.25(C), and because it was clear that Appellant was not entitled to immediate release. The Supreme Court affirmed, holding that the court of appeals correctly dismissed Appellant's petition for noncompliance with section 2969.25(C). View "State ex rel. Ellis v. Wainwright" on Justia Law

The Supreme Court reversed the judgments of the court of appeals in this construction dispute, holding that Ohio's construction statute of repose, Ohio Rev. Code 2305.131, applies to any cause of action, whether sounding in contract or tort, so long as the cause of action meets the requirements of the statute.Plaintiff filed this action against several defendants, companies involved in the design and construction of a public school building, alleging claims for breach of contract. Defendants argued that the statute of repose on section 2305.131 barred Plaintiff's claims because substantial completion of the project occurred more than ten years before the claims were filed. The trial court agreed and dismissed the claims as time barred. The court of appeals reversed, concluding that section 2305.131 does not apply to breach of contract claims. The Supreme Court reversed, holding that section 2305.131 applies to both contract and tort claims. View "New Riegel Local School District Board of Education v. Buehrer Group Architecture & Engineering, Inc." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's action seeking a writ of mandamus to compel Judge Christine Croce to vacate his sentences, merge certain offenses, and resentence him, holding that Appellant could have raised his claims by appealing his sentence.Appellant pleaded guilty to aggravated burglary, felonious assault, rape and kidnapping. Finding that Appellant's offenses were separate and should not be merged at sentencing the trial court imposed a prison term for each offense and ordered the terms to be served consecutively. Appellant later filed his mandamus action. The court of appeals dismissed the complaint, determining that Appellant had an adequate remedy at law. The Supreme Court affirmed, holding that the court of appeals correctly determined that Appellant did not lack an adequate remedy in the ordinary course of the law because he could have raised his claims by appealing his sentence. View "State ex rel. Cowell v. Croce" on Justia Law

The Supreme Court denied a writ of prohibition sought by the Ohio High School Athletic Association (OHSAA) to prohibit Judge Robert Ruehlman from taking further action in a lawsuit filed against it in the Hamilton County Court of Common Pleas, holding that Judge Ruehlman did not patently and unambiguously lack jurisdiction.After the OHSAA adopted new rules governing postseason competitions Judge Ruehlman granted a temporary restraining order enjoining the application of the rules in cases where the high school enrolled a student who attended seventh and eighth grades at one of its traditional Catholic Feeder Schools. The OHSAA then filed this action to prevent Judge Ruehlman from taking further action in the case and to order him to vacate the temporary restraining order. The Supreme Court denied the writ, holding that the subject matter of this dispute fell within the jurisdiction granted by the Ohio Constitution and Revised Code to the Hamilton County Court of Common Pleas and that Judge Ruehlman properly exercised the subject-matter jurisdiction of the Hamilton County Court of Common Pleas. View "Ohio High School Athletic Ass'n v. Ruehlman" on Justia Law

The Supreme Court granted a writ of mandamus ordering the Franklin County Board of Elections to reinstate Robert Bender's certification to the November 2019 ballot as the Libertarian Party candidate for Reynoldsburg City Council, Ward 3, holding that the Board abused its discretion by removing Bender from the ballot.Although the Board initially certified Bender to the ballot, it sustained a protest challenging the validity of some of the signatures on Bender's petition. The Supreme Court granted a writ of mandamus ordering the Board to reinstate Bender as a candidate for the November 2019 general election, holding that no evidence established that the protestor had standing to bring the protest and that the time for sua sponte action by the Board had passed. View "State ex rel. Bender v. Franklin County Board of Elections" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's order confirming the sale of Homeowners' property after the trial court entered a foreclosure decree in favor of Bank, holding that the foreclosure decree was a final, appealable order.Homeowners challenged the trial court's entry of a foreclosure decree in favor Bank. The court of appeals dismissed the appeal for lack of a final, appealable order because the foreclosure decree did not state the amounts owed to two other lienholders. During the appeal, Homeowners' property was sold at a sheriff's sale. Homeowners' second appeal challenged the trial court's order confirming the sale of the property. The court of appeals concluded that the law-of-the-case doctrine required adherence to its earlier decision that the foreclosure decree was not a final, appealable order, and therefore, the trial court had no authority to confirm the sale. The Supreme Court reversed and reinstated the trial court's confirmation of sale, holding that the foreclosure decree against Homeowners was a final, appealable order that fully addressed the rights and responsibilities of all parties. View "Farmers State Bank v. Sponaugle" on Justia Law

The Supreme Court granted a writ of prohibition and denied a requested writ of mandamus in this original action by WBNS 10-TV, Inc. against Franklin County Common Pleas Domestic Relations Court Judge Monica Hawkins, holding that prohibition was the proper vehicle to challenge the order denying courtroom access to 10-TV that was issued by Judge Hawkins without an evidentiary hearing and that this decision rendered moot 10-TV's alternative request for a writ of mandamus.After Judge Hawkins was arrested for driving under the influence a reporter for 10-TV made a written request for media access to the proceedings in Judge Hawkins's courtroom scheduled for that same day. Judge Hawkins denied the request without conducting the required closure hearing. 10-TV then commenced an original action seeking writs of prohibition and mandamus. In response, Judge Hawkins agreed that a writ of prohibition should issue. The Supreme Court granted the writ of prohibition, denied the request for a writ of mandamus as moot, and denied the requests in 10-TV's emergency motion for peremptory writs of prohibition and mandamus as moot. View "State ex rel. WBNS 10-TV, Inc. v. Hawkins" on Justia Law