Justia Labor & Employment Law Opinion Summaries

Marcus Pryor applied to the Ohio Department of Job and Family Services (ODJFS) for unemployment compensation. The director of ODJFS concluded that Pryor was ineligible for benefits. A hearing officer with the Unemployment Compensation Review Commission affirmed. The Commission denied Pryor’s request to review the hearing officer’s findings. Pryor filed an appeal in the common pleas court naming the director of ODJFS as the appellee but failing to name the Army, Pryor’s former employer, as a party to his appeal. The common pleas court dismissed the appeal, finding that because Pryor failed to name the Army was an interested party, his notice of appeal did not comply with Ohio Rev. Code 4141.282(D), thus depriving the court of subject-matter jurisdiction. The court of appeals reversed the common pleas court’s dismissal of Pryor’s appeal and reinstated Pryor’s administrative appeal in the common pleas court, ruling that Pryor’s failure to name the Army was not a jurisdictional defect. The Supreme Court reversed, holding (1) the naming of interested parties is not a jurisdictional requirement under section 4141.282; but (2) the Commission failed to comply with the procedural requirements in section 4141.282(D), and therefore, Pryor’s time to appeal the Commission’s decision never started to run. Remanded. View "Pryor v. Dir., Ohio Dep’t of Job & Family Servs." on Justia Law

Daniel Stolz worked for a subcontractor on a construction project when he was injured in an accident on the job site. Prior to the accident, Messer had obtained authority from the Ohio Bureau of Workers’ Compensation to act as the self-insuring employer on the project, which gave Messer responsibility for providing workers’ compensation coverage for its own employees as well as the employees of enrolled subcontractors on the project. Stolz brought negligence claims against Messer Construction, the general contractor, and several subcontractors. A federal district court granted summary judgment to Messer as the self-insuring employer but denied summary judgment to the subcontractors, concluding that an enrolled subcontractor on a self-insured construction project is immune from claims made by its own employees but not from those made by employees of other enrolled subcontractors. The federal court then certified a question of state law to the Supreme Court. The Supreme Court answered that subcontractors enrolled in a self-insured construction project plan are immune from tort claims for workplace injuries from employees of other enrolled subcontractors on the same project. View "Stolz v. J & B Steel Erectors, Inc." on Justia Law

Robert Boyd retired from Scotts Miracle-Gro Company in 1983. Boyd received workers’ compensation benefits in 2005 for asbestosis in both lungs. In 2013, Boyd applied for permanent-total-disability benefits. A staff hearing officer at the Industrial Commission denied Boyd’s application. Boyd then filed a complaint seeking a writ of mandamus that would require the Commission to vacate its decision. The court of appeals denied the writ. The Supreme Court affirmed, holding that Boyd’s complaint in mandamus failed where Boyd failed to demonstrate that the Commission abused its discretion by entering an order not supported by any evidence in the record. View "State ex rel. Boyd v. Scotts Miracle-Gro Co." on Justia Law

Appellees were employed as sales representatives by a company that was owned by Appellants. Appellants filed a class action lawsuit seeking a declaration that certain provisions of Ohio Rev. Code 4111.14 were unconstitutional and a declaration that, as employees, they were entitled to minimum wage. Specifically, Appellants argued (1) because Ohio Rev. Code 4111.14(B)(1) contains exemptions from the definition of “employee” that Ohio Constitution, Article II, Section 34a does not contain, the statute is unconstitutional; and (2) section 4111.14(B) does not apply to claims for minimum wage violations brought under the Constitution. The trial court declared that section 411.14(B)(1) is constitutionally valid and that the exemptions within the statute apply to claims brought under Article II, Section 34a. The Court of Appeals reversed, concluding that the General Assembly exceeded its authority when it defined “employee” differently, and more narrowly, than did the Constitution. The Supreme Court reversed, holding that section 4111.14(B)(1) is constitutional because its definition of the term “employee” does not clearly conflict with the definition of the same term set forth in Article II, Section 34a. View "Haight v. Minchak" on Justia Law

The Ohio Board of Nursing commenced a professional disciplinary action against Beverly Clayton, a staff nurse in the intensive care unit (ICU) of Mercy Hospital Western Hills, for alleged violations of Ohio Rev. Code 4723. In a number of separate motions, Clayton requested subpoenas for the personal appearance of numerous people and subpoenas duces tecum seeking to obtain several different collections of documents. The Board filed a motion to limit subpoena request, arguing that the number of requests was successive. The hearing examiner denied the Board’s motion in large part but granted the request with respect to certain ICU patient records. After a hearing, the hearing examiner concluded that discipline was warranted. The trial court affirmed the Board’s decision. The court of appeals affirmed, implying that the hearing examiner’s decision to limit the subpoena may have been erroneous but that Clayton failed to establish prejudice. The Supreme Court affirmed, holding (1) a hearing examiner for the Board of Nursing has the discretion to limit or quash subpoenas requested during disciplinary proceedings; and (2) the hearing examiner’s decision to limit Clayton’s subpoena duces tecum in this case was not an abuse of discretion. View "Clayton v. Ohio Bd. of Nursing" on Justia Law

Plaintiffs, former correctional institution employees and a labor union, filed this action against numerous government Defendants, alleging that 2011 Am.Sub.H.B. No. 153, the budget bill for the 2012-2013 biennium, violates the Ohio Constitution. H.B. 153 modified prior law governing contracts for the private operation and management of a state correctional institution in several ways. The court of common pleas granted Defendants’ motion to dismiss, concluding (1) the court lacked jurisdiction to determine whether employees of privately owned or operated prisons were employees, as defined by Ohio Rev. Code 4117.01(C); and (2) the court had jurisdiction over the constitutional challenges to H.B. 153, but Plaintiffs failed to state a claim that H.B. 153 was unconstitutional. The court of appeals reversed in part and ordered the trial court to hold an evidentiary hearing to determine whether H.B. 153 violates the one-subject rule in Ohio Const. art. II, 15(D). The Supreme Court affirmed in part and reversed in part, holding (1) H.B. 153 is constitutional; and (2) the State Employee Relations Board has exclusive jurisdiction to determine public-employee status under section 4117.01(C). View "State ex rel. Ohio Civil Serv. Employees Ass’n v. State" on Justia Law

Robert Mason was injured while working as a truck driver for Old Dominion Freight Line, Inc. Mason later applied for permanent-total-disability compensation. The Industrial Commission of Ohio granted Mason’s application based on the reports of two Commission specialists. Old Dominion filed a complaint for a writ of mandamus that would require the Commission to vacate its award of permanent-total-disability compensation, maintaining that the reports were flawed because the doctors did not review the defense medical reports in advance of their independent medical examinations. The court of appeals denied the writ. The Supreme Court affirmed, holding (1) Old Dominion’s request to depose the doctors was not reasonable; and (2) the reports constituted some evidence of permanent total disability, and therefore, Old Dominion failed to establish a clear legal right to the relief requested and a clear legal duty on the part of the Commission to provide such relief. View "State ex rel. Old Dominion Freight Line, Inc. v. Indus. Comm’n" on Justia Law

In 1994, Appellant was injured in the course and scope of his employment. In 2010, during the course and scope of his employment for a new employer, Appellant was injured. In 2012, Appellant requested temporary-total-disability compensation for the period beginning December 8, 2011. The Industrial Commission denied compensation, concluding that Appellant had not presented persuasive medical evidence establishing that Appellant’s 1994 industrial injury rendered him temporarily and totally disabled as of December 8, 2011. Appellant filed a complaint seeking a writ of mandamus that would require the Commission to vacate its order denying compensation and to award temporary-total-disability benefits beginning December 8, 2011. The court of appeals denied the writ. The Supreme Court affirmed, holding that the Commission did not abuse its discretion when it denied Appellant’s request for compensation for the period beginning December 8, 2011. View "State ex rel. Ritzie v. Reece-Campbell, Inc." on Justia Law

Employee was injured during the course of his employment with Precision Steel Services, Inc. Employee received compensation for his medical expenses and lost wages. Two years after the accident, Employee applied for an additional award for violation of a specific safety requirement (VSSR). The Industrial Commission granted a VSSR award to Employee, determining that Precision Steel violated the safety regulations in Ohio Adm. Code 4123:1-5-14(G)(1) and 4123:1-5-15(B) and that those violations proximately caused Employee’s injury. Precision Steel then filed this mandamus action. The court of appeals issued a limited writ, concluding that Precision Steel violated Ohio Adm. Code 4123:1-5-15(B) and ordering that the Commission readjudicate Employee’s claim based on Ohio Adm. Code 4123:1-5-14(G)(1). The Supreme Court reversed and granted a writ of mandamus requiring the Commission to vacate its order and to issue a new order denying Employee’s application for an additional award for VSSR, holding (1) neither Ohio Adm. Code 4123:1-5-14(G) nor 4123:1-5-15(B) establishes a specific safety requirement in the context of this case; and (2) therefore, the Commission’s decision that Precision Steel violated the rules was an abuse of discretion. View "State ex rel. Precision Steel Servs., Inc. v. Indus. Comm’n" on Justia Law

Employee, an ironworker, was injured in a fall while working for Employer, a subcontractor on a bridge project. Employee’s workers’ compensation claim was allowed for multiple injuries sustained in the fall. Two years after the incident, Employee applied for an additional award for Employer’s violation of a specific safety requirement (VSSR), alleging that his fall was caused by Employer’s violation of numerous specific safety regulations. A staff hearing officer with the Industrial Commission granted a VSSR award. Employer filed a complaint and an amended complaint in mandamus, seeking a writ that would compel the Commission to vacate its order and to refund all additional compensation that had been paid by Employer as a result the VSSR award. Employer asserted that the Commission abused its discretion by finding that Employer violated a specific safety requirement because Employee’s injuries were the result of his failure to wear the appropriate personal protective equipment. The court of appeals denied the writ. The Supreme Court affirmed, holding that the Commission did not abuse its discretion when it issued a VSSR award, and therefore, the court of appeals properly denied Employee’s request for a writ of mandamus. View "State ex rel. Armstrong Steel Erectors, Inc. v. Indus. Comm’n" on Justia Law