Justia Labor & Employment Law Opinion Summaries

Articles Posted in Supreme Court of Ohio
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The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus against Youngstown Mayo Jamael Tito Brown, Youngstown Fire Chief Barry Finley, and Youngstown Finance Director Kyle Miasek (collectively, the officials), holding that Appellant had a remedy in the ordinary course of the law.Appellant, a captain in Youngstown's fire department, and his union filed a grievance against the city alleging that he city had violated the parties' collective bargaining agreement (CBA) by not timely promoting him to battalion chief. The grievance was denied, and the union did not seek further relief. Appellant brought this complaint. The court of appeals dismissed the complaint on the grounds that Appellant had an adequate remedy at law. The Supreme Court affirmed, holding that the court of appeals correctly concluded that Appellant had an adequate remedy in the ordinary course of the law. View "State ex rel. Casey v. Brown" on Justia Law

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The Supreme Court denied Relator's petition in this original action seeking a writ of mandamus to compel the city of Sheffield Lake and its mayor (collectively, the city) to produce documents in response to a public records request sent by Relator, holding that Relator failed to establish that he was entitled to the requested relief.Relator, a city police officer and the city's only black officer at the time, submitted a public records request for records relating to an incident in which Anthony Campo, the city's former police chief, resigned after placing a "KKK" sign across the back of Relator's coat to cover the word "POLICE," donned a paper KKK hat and told Relator he should wear one on his next police call. The city provided only partial responses to the request. Relator then brought this mandamus action. The Supreme Court denied relief, holding (1) the evidence showed that the city made reasonable efforts to locate the documents; and (2) Relator's requests for awards of statutory damages, attorney fees, and court costs are also denied. View "State ex rel. Pool v. Sheffield Lake" on Justia Law

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The Supreme Court reversed the decision of the court of appeals reversing the order issued by the Ohio Bureau of Workers' Compensation classifying the in-home direct-care workers of Friendship Supported Living, Inc. as employees rather than independent contractors, holding that the Bureau abused its discretion.Friendship protested the findings of the Bureau in its 2017 premium audit for the 2014-2015 period, arguing that Friendship's in-home direct-care workers were independent contractors rather than employees. The findings were affirmed. Thereafter, Friendship filed a complaint for a writ of mandamus seeking an order directing the Bureau to classify its in-home direct-care workers as independent contractors and reimburse Friendship for premiums it had made as a result of the Bureau's classification. The court of appeals granted a writ of mandamus. The Supreme Court reversed and granted a limit writ of mandamus ordering the Bureau to issue an amended order, holding that the Bureau abused its discretion by failing sufficiently to account for the pertinent factors bearing on the relationship between Friendship and its direct-care workers. View "State ex rel. Friendship Supported Living, Inc. v. Ohio Bureau of Workers' Compensation" on Justia Law

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The Supreme Court granted writs of prohibition and mandamus ordering Judge John P. O'Donnell of the Cuyahoga County Common Pleas Court to stop exercising jurisdiction over the underlying case and to dismiss the underlying case, holding that the Ohio Bureau of Workers' Compensation was entitled to the writs.The City of Cleveland and the City of Parma sued the Bureau in separate actions. The Supreme Court held that the court of claims had exclusive jurisdiction over Cleveland's action. Judge O'Donnell then dismissed Parma's action for lack of subject matter jurisdiction. Thereafter, Parma filed the underlying lawsuit seeking a declaratory judgment. Judge O'Donnell denied the Bureau's motion to dismiss. Parma also filed an action against the Bureau in the court of claims, which dismissed the complaint on limitations grounds. The Bureau then brought this action against Judge O'Donnell, arguing that the common pleas court patently and unambiguously lacked jurisdiction over the underlying case. The Supreme Court granted relief, holding that the Court of Claims Act, Ohio Rev. Code 2743.01 et seq., patently and unambiguously divested the common pleas court of jurisdiction. View "State ex rel. Ohio Bureau of Workers' Compensation v. O'Donnell" on Justia Law

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The Supreme Court affirmed the judgment of court of appeals denying a writ of mandamus sought by Waste Management of Ohio, Inc. ordering the Industrial Commission of Ohio to reverse its decision granting T.A.'s application for benefits, holding that the Commission did not abuse its discretion.Travis Gelhausen died shortly after getting into an accident while driving a truck for Waste Management of Ohio, Inc. T.A. applied for benefits on behalf of her and Gelhausen's minor daughter, S.G., for Gelhausen's loss of the use of his arms and legs before his death. The Commission granted the application. Waste Management sought a writ of mandamus ordering the Commission either to vacate its award or to limit the award. The court of appeals denied the writ. The Supreme Court affirmed, holding that the Commission's award was proper. View "State ex rel. Waste Management of Ohio, Inc. v. Industrial Commission" on Justia Law

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The Supreme Court affirmed the court of appeals' decision reversing the trial court's judgment for Plaintiff after denying the motion for summary judgment filed by Defendant, the manufacturing company Johns Manville, holding that the court of appeals did not err in applying the relevant law when reviewing John Manville's motion for summary judgment.Plaintiff brought this action alleging that Johns Manville intentionally caused her husband to be injured while working. After the trial court denied Johns Manville's motion for summary judgment the jury found in favor of Plaintiff. The court of appeals reversed, holding that summary judgment should have been granted in John Manville's favor and that the case should not have been given to the jury. The Supreme Court affirmed after reaffirming that when reviewing a trial court's decision to deny summary judgment in cases in which a jury ultimately reached a verdict in the nonmoving party's favor, an appellate court must construe the evidence most strongly in favor of the nonmoving party when applying the law, holding that the court of appeals did not err in its review. View "Bliss v. Johns Manville" on Justia Law

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The Supreme Court denied a writ of mandamus sought by Walmart, Inc. ordering the Industrial Commission of Ohio to reverse its decision awarding Dianna Hixson temporary total disability (TTD) compensation on the basis of State ex rel. Klein v. Precision Excavating & Grading Co., 119 N.E.3d 386 (Ohio 2018), holding that Klein applies prospectively only.Before the Supreme Court issued Klein, the Commission awarded Hixson TTD compensation. After Klein was released, Walmart, Hixson's former employer, filed this action seeking a writ of mandamus ordering the termination of Hixson's TTD compensation after the date notified Walmart of her retirement. The court of appeals granted the writ, concluding that the Commission abused its discretion by awarding TTD compensation for the period following Hixson's retirement. The Supreme Court reversed, holding that Klein does not apply retroactively and should be applied prospectively only. View "State ex rel. Walmart, Inc. v. Hixson" on Justia Law

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In this original action involving a dispute between Relator, Lake County Clerk of Courts Faith Andrews, and Respondents, the seven judges of the Lake County Court of Common Pleas, the Supreme Court granted a writ of prohibition vacating Respondents' May 2022 journal entry and prohibiting the judges from imposing similar restrictions against Relator without jurisdiction, holding that Relator was entitled to the writ.Relator's alleged misconduct within the clerk's office led Respondents to issue a journey entry in May 2022 that banned Relator from entering the Lake County courthouse except for one day per month. Relator brought this action seeking writs of prohibition, mandamus, or quo warrant to prevent the judges from interfering with her execution of her duties at the courthouse, where the clerk's office was located. The Supreme Court issued a writ of prohibition vacating Respondents' journal entry, issued a writ of mandamus ordering Respondents to vacate the May 2022 entry, and denied as moot Relator's request for a writ of quo warranto, holding that Respondents effectively removed Relator from her office without jurisdiction to do so. View "State ex rel. Andrews v. Lake County Court of Common Pleas" on Justia Law

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The Supreme Court reversed the decision of the court of appeals determining that one need not be prejudiced to be an "adversely affected" party, as that phrase is used in Ohio Rev. Code 119.12(I), holding that the phrase "adversely affected" as used in the statute imposes a prejudice requirement.After the State Personnel Board of Review ordered that Kristy Goudy be reinstated to her position at the Tuscarawas County Public Defender's Office, the public defender's office appealed. The personnel board, however, failed timely to certify a complete record. It subsequently corrected the error and certified the remainder of the record outside the allotted time. The court of common pleas ruled that the public defender's office was not an adversely affected party because the delay in certifying the record did not cause any prejudice to the office. The court of appeals reversed. The Supreme Court reversed, holding (1) the court of appeals erred in concluding that section 119.12(I) does not contain a prejudice requirement; and (2) prejudice was not shown in this case. View "Goudy v. Tuscarawas County Public Defender" on Justia Law

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The Supreme Court reversed the judgment of the court of appeals granting a writ of mandamus ordering the Industrial Commission of Ohio to reverse its decision awarding Appellant temporary-total-disability (TTD) compensation after sustaining a work injury, holding that the Commission's order was neither unsupported by evidence in the record nor was it contrary to law.Appellant gave Appellee two weeks' notice of her intention to resign and subsequently sustained a work injury. The Commission awarded Appellant TTD compensation. The court of appeals granted a writ ordering the Commission to reverse its decision because Appellant had resigned from her employment prior to her injury. Relying on the Supreme Court's opinion in State ex rel. Klein v. Precision Excavating & Grading Co., 119 N.E.3d 386 (Ohio 2018), the court of appeals granted the writ. The Supreme Court reversed, holding (1) the decision in Klein did not redefine voluntary abandonment of the workforce as voluntary abandonment of the injured worker's position; and (2) the Commission did not abuse its discretion in determining that, but for her work injury, Appellant would have remained gainfully employed. View "State ex rel. Ohio State University v. Pratt" on Justia Law