Justia Ohio Supreme Court Opinion Summaries

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

Appellant, an inmate at Lorain Correctional Institution, sent Appellee, the warden of the institution, a public-records request to copy and inspect the Ohio Department of Rehabilitation and Correction employee rules of conduct. Appellant asserted that the requests were ignored. Appellant subsequently petitioned the court of appeals for a writ of mandamus against Appellee. The court of appeals dismissed the claim, finding that Appellant had failed to comply with Ohio Rev. Code 2969.25(C). Appellant filed a Ohio R. Civ. P. 60(B) motion seeking leave to amend his complaint, which the court also denied. The Supreme Court affirmed, holding that the court of appeals did not err in (1) dismissing the complaint due to Appellant’s failure to comply with section 2969.25; and (2) denying Appellant’s Rule 60(B) motion, as the failure to comply with the mandatory requirements of section 2969.25(C) is not curable by subsequent amendment. View "State ex rel. Young v. Clipper" on Justia Law

Based on investigations by law enforcement officials, a grand jury returned an indictment against several individuals and companies alleging that they had used an Internet gambling system to conceal illegal gambling by presenting it as an Internet sweepstakes. The prosecuting attorney then mailed letters to Plaintiff and other proprietors of Internet sweepstakes cafes threatening criminal prosecution if they did not immediately cease to run the sweepstakes. Plaintiff filed this action seeking to prohibit the prosecuting attorney from enforcing gambling laws against it with respect to Internet sweepstakes. Plaintiff sought to compel discovery of information related to the ongoing criminal investigation. The trial court ordered the prosecuting attorney to produce the information. The prosecuting attorney filed an interlocutory appeal. The court of appeals balanced the competing interests of Plaintiff and the prosecuting attorney and affirmed in part and reversed in part, holding that certain information being sought was not protected by the law enforcement investigatory privilege. The Supreme Court affirmed, holding (1) the law enforcement investigatory privilege is not absolute; and (2) the balancing test the Court adopted in Henneman v. Toledo for weighing the interests of law enforcement in keeping the information confidential against the needs of a civil litigant who requests the information in discovery remains valid. View "J & C Marketing, LLC v. McGinty" 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

Appellant was injured during the scope of his employment. In 2010, the Industrial Commission of Ohio found that Appellant had a six percent permanent partial disability and granted him compensation accordingly. In 2010, the Commission increased the award by four percent for a total of ten percent permanent partial disability. In 2011, the Commission again amended Appellant’s claim to include an additional condition and increased the award by an additional four percent. Appellant filed a complaint in mandamus alleging that the Commission’s order awarding only a four percent increase was not supported by the evidence. The court of appeals denied the writ. The Supreme Court affirmed, holding that the Commission did not abuse its discretion in adopting a percentage of disability that fell within the range suggested by two doctors. View "State ex rel. Romero v. River City Drywall Supply, Inc." on Justia Law

In 2004 and 2007, two fires broke out in two separate buildings of the Village Green Apartments. Plaintiffs, tenants of the apartment complex, filed suit against the apartment complex’s landlords, claiming that the buildings had been negligently constructed. The landlords were found liable. The jury awarded compensatory damages of $582,146, punitive damages of $2,000,000, and attorney fees of $1,040,000. The court of appeals affirmed. The Supreme court affirmed with respect to all issues except the award of punitive damages, holding (1) the amount of punitive damages exceeded the limit prescribed by Ohio Rev. Code 2315.21(D)(2)(a); (2) the trial court did not abuse its discretion in allowing the issue of punitive damages to go to the jury; and (3) the trial court did not abuse its discretion in allowing the jury to determine that the landlords had failed to comply with Ohio Rev. Code 5321.04 for failure to correct defects occurring in electrical wiring. View "Sivit v. Village Green of Beachwood, L.P." on Justia Law

Karen Baker, represented by an attorney with Schiavoni, Bush & Muldowney Co, L.P.A. (“the law firm”), filed an application for an increase in her permanent-partial-disability compensation. The Bureau of Workers’ Compensation awarded a total amount of $24,649.50. The law firm subsequently filed a motion with the Bureau seeking payment of its attorney fees out of Baker’s permanent-partial-disability-compensation award. The matter was referred to the full Industrial Commission, which denied the law firm’s motion, determining that it lacked jurisdiction to resolve a fee dispute between a claimant’s counsel and the Bureau and lacked jurisdiction to order the Bureau to pay the requested attorney fees. Baker then filed a complaint in mandamus against the Commission. The Court of Appeals denied the writ. The Supreme Court affirmed, holding that Baker and the law firm failed to demonstrate that they had a clear legal right to the relief requested or that the Bureau had a clear duty to pay the fees. View "State ex rel. Baker v. Indus. Comm’n" on Justia Law

In these consolidated appeals, the Supreme Court considered a trial court’s authority to “conditionally” dismiss a civil case and thereby retain jurisdiction to thereafter enforce a settlement between the parties. These two cases involved claims that arose as a result of a fire in an apartment complex. During a pretrial settlement conference, the parties orally agreed to settle their claims. The trial court sua sponte filed a dismissal entry. The court subsequently clarified that its dismissal was conditional and that it retained jurisdiction to enforce the settlement between the parties. The court of appeals concluded that the trial court’s dismissal entry divested the trial court of jurisdiction and precluded further proceedings. The Supreme Court affirmed, holding (1) a trial court may, when it dismisses a civil action upon notification that the parties have settled, expressly retain jurisdiction for the specific purpose of enforcing the settlement agreement; and (2) because the trial court’s dismissal entry in this case did not incorporate the terms of the settlement agreement or expressly state that the court was retaining jurisdiction to enforce the settlement agreement, the dismissal entry divested the court of jurisdiction and precluded further proceedings. View "Infinite Sec. Solutions, LLC v. Karam Props. II, Ltd." on Justia Law

Charles Watkins, an inmate at North Central Correctional Complex, filed an original action in mandamus against the chief of the Adult Parole Authority and chair of the Parole Board (together, Appellees), arguing that Appellees failed to affirm him review of his parole. The court of appeals dismissed the complaint sua sponte because Watkins’s affidavit did not comply with Ohio Rev. Code 2969.25(A)(1). The Supreme Court affirmed, holding that the court of appeals did not err by dismissing Watkins’s complaint sua sponte because it did not comply with the statute. View "State ex rel. Watkins v. Andrews" on Justia Law

David Quolke, the president of the Cleveland Teacher’s Union, requested from the Strongsville City School District Board of Education the names and identification numbers of all teachers and replacement teachers employed by the Board during a teachers’ strike. The Board claimed that many of the records were not subject to disclosure, asserting that the names of the replacement teachers were not considered public record because of the threat of harm to those teachers. Quolke sued in mandamus in the court of appeals for the records. The court of appeals found for Quolke and ordered the Board to produce the names. The Supreme Court affirmed, holding that, while there may have been a genuine threat to the replacement teachers’ well-being during the strike, the Board presented little evidence that there was any remaining threat to the teachers now that the strike was over. View "State ex rel. Quolke v. Strongsville City Sch. Dist. Bd. of Educ." on Justia Law