Justia Ohio Supreme Court Opinion Summaries

Appellant Aaron Rents, Inc. (ARI) challenged an order from the Ohio Bureau of Workers' Compensation that retroactively reclassified the jobs of certain ARI employees for purposes of workers' compensation premiums. ARI objected to the retroactive reclassification and argued that the bureau had abused its discretion by failing to adequately explain why it rejected ARI's request for prospective reclassification only. The court of appeals denied ARI's writ of mandamus. On appeal, the Supreme Court found that (1) ARI's ability to challenge the bureau's decision was compromised because the order did not explain why retroactive rather than prospective reclassification was favored and (2) further explanation was required as to why the bureau reached its decision in order for the court to determine whether an abuse of discretion occurred. The Court vacated the judgment of the appellate court and granted a limited writ ordering the bureau to vacate its order and issue an amended order including an explanation for its decision. View "State ex rel. Aaron Rents, Inc. v. Ohio Bureau of Workers Comp." on Justia Law

Defendant Gary Adkins was convicted of a violation of operating a motor vehicle while under the influence of alcohol (OVI). The trial court found that pursuant to Ohio Rev. Code 4511.19(G)(1)(d) Adkins had been convicted of five or more OVI offenses within the previous 20 years, including a prior juvenile adjudication, making his conviction for an OVI a fourth-degree felony. Pursuant to R.C. 2901.08, effective January 1, 1996, a prior juvenile adjudication constitutes a prior conviction for purposes of Ohio Rev. Code 4511.19(G)(1)(d). Adkins appealed, contending that his juvenile adjudication, which occurred before the effective date of Ohio Rev. Code 2901.08, should not be considered a prior conviction and that an application of Ohio Rev. Code 4511.19(G)(1)(d) to his case would require an unconstitutional retrospective application of Ohio Rev. Code 2901.08. The appellate court affirmed Adkins's conviction. The Supreme Court affirmed, holding that Ohio Rev. Code 2901.18 is applied prospectively and is not unconstitutionally retroactive. View "State v. Adkins" on Justia Law

Appellant Michael Patton sought a writ of mandamus directing Dusty Rhodes, the county auditor, to provide him with access to the county's financial reports for several years pursuant to Ohio Rev. Code Ann. 149.43, Ohio's public records act. The court of appeals dismissed Patton's mandamus action as moot in that Patton received access to the requested records when the records were posted on the county auditor's website. The appellate court also denied Patton's request for statutory damages and attorney fees. The Supreme Court affirmed, holding (1) the court of appeals correctly held that the county auditor satisfied Patton's request by posting copies of the records online within a reasonable period of time pursuant to Section 149.43; and (2) because Patton failed to establish that the county auditor failed to comply with an obligation in accordance with Section 149.43, he was also not entitled to an award of statutory damages. View "State ex rel. Patton v. Rhodes" on Justia Law

Property owner Riser Foods Company appealed a decision of the Board of Tax Appeals (BTA) in which the BTA determined the true value of Riser's real estate to be $450,000 for tax year 2005 rather than $73,700 as determined by the county auditor and the County Board of Revision (BOR). The BTA's determination of value was predicated on the price paid for the property in 2005 in accordance with a buy-out option agreed to by the parties in a ground lease. The ground lease was entered into in 1998, and ownership was transferred in 2005. The BTA regarded the buy-out-option price as a recent, arm's-length sale price that furnished the criterion of value for the property as of 2005 pursuant to Ohio Rev. Code 4713.03. The Supreme Court affirmed the decision of the BTA, holding (1) Riser had the initial burden to show that the 2005 sale was either not recent or not at arm's length; (2) Riser failed to negate the recency of the sale; and (3) Riser did not show that the long-standing contractual obligation to purchase made the sale involuntary or that a lack of open-market elements was significant. View "N. Royalton City Sch. Dist. Bd. of Educ. v. Cuyahoga County Bd. of Revision" on Justia Law

Appellant Cheryl Waiters was employed by the city of Cleveland. When the city discharged Waiters from employment, the union of which Waiters was a member filed a grievance and later demanded arbitration. The arbitrator found the city had discharged Waiters without just cause and ordered that she be reinstated to employment. Waiters then filed a complaint in the court of appeals for a writ of mandamus to compel her reinstatement to her former position with back pay and an award of attorney fees. The city subsequently reinstated Waiters to her former job. The court of appeals denied Waiters's writ, concluding that her claim for reinstatement was moot and that she failed to establish her entitlement to back pay or attorney fees. Waiters appealed. The Supreme Court affirmed the judgment of the court of appeals, holding that (1) Waiters's reinstatement claim was rendered moot when she was reinstated; (2) as a bargaining-unit employee who was represented by the union in the grievance and arbitration process, Waiters was relegated to the arbitration proceeding in which the dispute concerning the amount of back pay she would be entitled to was being decided; and (3) Waiters was not entitled to attorney fees. View "State ex rel. Waiters v. Szabo" on Justia Law

Appellant Juan Lackey, who drove trucks for Penske Truck Leasing Company, injured his knee at work. After surgery was performed, Lackey returned to work and filed retirement papers with Penske. Nothing in his retirement documents indicted that Lackey's retirement was connected to the industrial injury. Following his retirement, Lackey requested temporary total disability compensation (TTC). A district hearing officer for Lackey, the state industrial commission, denied the request, finding Lackey had voluntarily retired for reasons unrelated to his injury and Lackey's retirement constituted a voluntary abandonment of the entire labor market. On appeal, a staff hearing officer affirmed. Lackey appealed to the commission, and the commission denied the appeal. The court of appeals denied Lackey's mandamus action after finding the commission's findings were supported by evidence. On appeal, the Supreme Court affirmed, holding the commission did not abuse its discretion in finding that Lackey's retirement was unrelated to his injury, and, accordingly, Lackey could receive postretirement TTC only if he were gainfully employed elsewhere and prevented from doing that job by his industrial injury. View "State ex rel. Lackey v. Indus. Comm'n" on Justia Law

During Greg Zeigler's tenure as Stark County treasurer, his chief deputy pleaded guilty to stealing almost $2.5 million from the treasurer's office, after which the county prosecutor instituted an recoupment action under Ohio Rev. Code Ann. 321.37. The board of commissioners then voted to remove Zeigler from office pursuant to Ohio Rev. Code Ann. 321.38, which permits the removal of the county treasurer by the board of commissioners upon institution of a suit under Section 321.37. Zeigler then filed an action for a writ of quo warranto to oust the current treasurer and to be reinstated as treasurer, arguing that Section 321.38 is unconstitutional. The Supreme Court granted the writ of quo warranto, holding (1) that because Section 321.38 does not require a complaint and hearing before authorizing a board of county commissioners to remove a county treasurer, it is unconstitutional; (2) the removal of Zeigler violated Ohio Const. art. 2, 38; and (3) Zeigler was entitled to serve the remainder of his elected term. View "State ex rel. Zeigler v. Zumbar" on Justia Law

The German Village Society (GVS) filed an application for exemption of real property. Pursuant to Ohio Rev. Code 5715.27(C), the school board became a party to the proceedings before the tax commission and to any appeal to the Board of Tax Appeals (BTA). After the tax commissioner denied GVS's application, GVS appealed to the BTA but did not serve the school board with its notice of appeal. BTA reversed the decision of the tax commissioner and granted the exemption but did not transmit its decision to the school board. The tax commissioner then issued a determination giving effect to the BTA's decision. The school board filed a notice of appeal from the tax commissioner's order, asserting that the BTA's decision was void ab initio because the school board was not named or notified as to the existence of the appeal. The BTA held that because the period for appeal from its decision had expired, it did not have jurisdiction to address the validity of its earlier decision. The Supreme Court reversed the BTA's holding that it had no jurisdiction to grant relief to the school board, vacated the BTA's decision along with the tax commissioner's related order, and remanded. View "Columbus City Schools Bd. of Educ. v. Testa" on Justia Law

After appellee Mary Williams was hired as a full-time residential social worker at appellant Bridgeway, Inc., a community mental health center, Bridgeway offered Williams a promotion. The promotion was conditioned on the requirement that Williams obtain certification as a Licensed Independent Social Worker (LISW) within 15 months. Because Williams did not obtain her LISW certification within the time required, she was terminated. Williams' application for unemployment compensation was disallowed by the Ohio Department of Job and Family Services, which determined that Williams had been discharged with just cause. On appeal, the Unemployment Compensation Review Commission affirmed. The court of common pleas denied Williams's subsequent appeal. The court of appeals reversed, holding that Williams's requirement to obtain an LISW certification was not fairly applied to other program managers. Bridgeway appealed. The Supreme Court reversed the judgment of the appellate court, holding that when employment is expressly conditioned upon obtaining or maintaining a license or certification and an employee agrees to the condition and is afforded a reasonable opportunity to obtain or maintain the license or certification, an employee's failure to comply with that condition is just cause for termination for unemployment compensation purposes. View "Williams v. Ohio Dep't of Job & Family Servs. " on Justia Law

Appellant Ruby Pula, a resident of Hawaii, was the custodian of the child of Adrienne Pula-Branch, a resident of Ohio. On Pula's behalf, the Cuyahoga Support Enforcement Agency (CSEA) filed a petition for child support and medical coverage against Pula-Branch under the Uniform Interstate Family Support Act (UIFSA). The domestic relations court issued a child-support order. The CSEA appealed, challenging the court's calculation of child-support obligations. The appellate court held that the domestic relations court had no jurisdiction to address a UIFSA support order because the lower court's jurisdiction was limited by Ohio Rev. Code Ann. 2301.03(L)(1) to matters involving divorce, dissolution of marriage, legal separation, or annulment. CSEA appealed. The Supreme Court reversed, holding that the domestic relations court does have jurisdiction over an action for support brought pursuant to the UIFSA, even if the action does not arise from one of the enumerated matters in the statute. View "Pula v. Pula-Branch" on Justia Law