Justia Civil Procedure Opinion Summaries

In 2015, Michael Shields, a mechanic for the Greater Cleveland Regional Transit Authority (RTA), injured his left shoulder. The Bureau of Workers’ Compensation approved his claim for left shoulder strain. In 2017, Shields sought benefits for a related right shoulder injury, which the bureau denied. Shields then sued in the Cuyahoga County Court of Common Pleas, and in May 2022, a jury found him entitled to benefits for the right shoulder injury. The RTA appealed, and the Eighth District Court of Appeals affirmed the decision on April 27, 2023.Following the appellate court's decision, Shields filed a motion on May 8, 2023, seeking $26,221 in appellate attorney fees or a remand to the trial court to determine the fees. The RTA opposed, arguing the motion was untimely and that Shields had waived the issue by not seeking fees earlier. The appellate court ruled in favor of Shields, allowing him to recover appellate attorney fees and remanded the case to the trial court to determine the amount.The Supreme Court of Ohio reviewed the case and affirmed the appellate court's decision. The court held that a worker who prevails at trial in a workers’ compensation action may request attorney fees after obtaining an appellate judgment on the merits. The court emphasized that the workers’ compensation statute should be liberally construed in favor of employees and found no statutory requirement for the timing of such a request. The court dismissed the RTA's arguments regarding the timing and jurisdiction of the fee request and did not address the issue of fee caps, as it was not ripe for review. View "Shields v. Bureau of Workers’ Compensation" on Justia Law

A medical-malpractice action was filed by Kalvyn Stull and his family against Summa Health System and associated parties, alleging that improper medical treatment following a car accident caused severe brain damage to Kalvyn. During discovery, the plaintiffs requested the residency file of Dr. Mazen Elashi, a resident physician involved in the treatment. Summa Health System claimed the file was protected by the peer-review privilege under Ohio law, supported by an affidavit from Dr. Erika Laipply, which stated that the file was used exclusively for peer-review purposes.The trial court in Summit County held that Summa had not sufficiently demonstrated that the peer-review privilege applied, as the affidavit contained ambiguities and lacked specific details. The court granted the motion to compel the production of the residency file. Summa appealed, and the Ninth District Court of Appeals affirmed the trial court's decision, agreeing that the affidavit was insufficient to establish the privilege due to its ambiguities and incomplete information.The Supreme Court of Ohio reviewed the case and held that the presence of factual ambiguities in affidavit testimony does not alone determine whether the peer-review privilege applies. The court emphasized that the trial court has the authority to conduct further inquiry, including in camera review, to resolve the factual disputes and determine the applicability of the privilege. The Supreme Court reversed the judgment of the Ninth District Court of Appeals and remanded the case to the trial court for an in camera review of the residency file and any other necessary factual inquiry to resolve the legal question of whether the file is privileged. View "Stull v. Summa Health System" on Justia Law

Paul Prinkey Jr. was injured while working for Emerine’s Towing, Inc. on January 19, 2015. His workers' compensation claim was allowed for myocardial infarction, substantial aggravation of pre-existing coronary artery disease, and major depressive disorder. Prinkey filed his first application for permanent-total-disability (PTD) compensation on February 4, 2019, which was denied by the Industrial Commission of Ohio based on medical evaluations indicating he was capable of sedentary work. Prinkey filed a second application for PTD compensation on June 4, 2021, citing worsening symptoms.The Industrial Commission denied Prinkey’s second application, stating he failed to present evidence of new and changed circumstances as required by the amended R.C. 4123.58(G). The commission's staff hearing officer (SHO) found no jurisdiction to address the application due to the lack of new evidence. Prinkey sought a writ of mandamus from the Tenth District Court of Appeals, which returned the matter to the commission for further proceedings, finding the SHO's order lacked adequate explanation and evidence.The Supreme Court of Ohio reviewed the case and affirmed the Tenth District's decision. The court held that the SHO failed to comply with the requirements of State ex rel. Noll v. Indus. Comm., which mandates that the commission must specifically state the evidence relied upon and briefly explain the reasoning for its decision. The court found that the SHO did not provide sufficient reasoning or cite specific evidence to support the conclusion that Prinkey failed to present new and changed circumstances. Consequently, the case was returned to the Industrial Commission for further proceedings. View "State ex rel. Prinkey v. Emerine's Towing, Inc." on Justia Law

George Martens filed a complaint in the Third District Court of Appeals for a writ of mandamus against various judges and courts in Hancock County, alleging that they lacked jurisdiction to decide certain tax cases. Martens did not allege that he was a party to any tax case pending before those courts when he filed this action. The judges and courts filed a motion to dismiss, arguing that Martens lacked standing and had not stated a cognizable mandamus claim.The Third District Court of Appeals dismissed the case, concluding that Martens lacked standing to bring the complaint and had failed to state a claim for mandamus relief. Martens appealed to the Supreme Court of Ohio, arguing that he did not need to meet the traditional standing requirement based on the public-right doctrine recognized in State ex rel. Ohio Academy of Trial Lawyers v. Sheward. Alternatively, he claimed taxpayer standing.The Supreme Court of Ohio rejected Martens's reliance on Sheward, overruling the public-right doctrine established in that case. The court held that Sheward was contrary to the deeply rooted standing requirement and the Ohio Constitution. The court also found that Martens could not establish taxpayer standing, as he had not shown any special interest in the public funds at issue or cited statutory authority authorizing him to bring a taxpayer suit. Consequently, the Supreme Court of Ohio affirmed the Third District's dismissal of Martens's complaint for lack of standing. View "State ex rel. Martens v. Findlay Municipal Court" on Justia Law

The City of Rittman filed an original action in prohibition against Judge Corey E. Spitler of the Wayne County Common Pleas Court. Rittman sought to prevent Judge Spitler from exercising jurisdiction over a class-action lawsuit in which Rittman was named as a defendant. The lawsuit, filed by Tara Boler and Trista Bise, alleged that Rittman had illegally collected a 0.5 percent income tax increase beyond its authorized period and sought refunds for the overcharged taxes from 2008 to 2022.In the Wayne County Common Pleas Court, Judge Spitler denied Rittman’s motion to dismiss and motion to stay discovery, and he established a case-management schedule. Rittman then sought a writ of prohibition from the Supreme Court of Ohio to stop Judge Spitler from proceeding with the case, arguing that the lawsuit was an impermissible attempt to bypass the statutory process for obtaining tax refunds.The Supreme Court of Ohio reviewed the case and determined that Judge Spitler had jurisdiction and statutory authority under R.C. 2723.01 to hear the case. The court found that the plaintiffs' claims were substantively governed by R.C. 2723.01, which allows common pleas courts to enjoin the illegal levy or collection of taxes and entertain actions to recover them when collected. The court concluded that although the plaintiffs did not explicitly invoke R.C. 2723, their claims fit within its scope. Therefore, the Supreme Court of Ohio denied the writ of prohibition, allowing Judge Spitler to continue exercising jurisdiction over the underlying case. View "State ex rel. Rittman v. Spitler" on Justia Law

The case involves Patricia A. Heilman, the surviving spouse of Arthur J. Heilman, who died from an industrial accident. Patricia Heilman sought scheduled-loss compensation under Ohio law, claiming her husband had lost the use of both arms, both legs, sight in both eyes, and hearing in both ears before his death. The Industrial Commission of Ohio denied her request based on a nonexamining physician's report, which did not fully accept the findings of the examining physicians.The Tenth District Court of Appeals reviewed the case and granted a limited writ of mandamus. The court ordered the Industrial Commission to vacate its denial of scheduled-loss compensation and to re-evaluate whether Patricia Heilman had established her claims under the relevant statute. The court found that the Commission had improperly relied on the nonexamining physician's report, which did not comply with the requirements set forth in Wallace v. Industrial Commission.The Supreme Court of Ohio reviewed the case and affirmed the Tenth District's judgment. The court held that the Industrial Commission abused its discretion by relying solely on the nonexamining physician's report, which failed to accept the objective findings of the examining physicians. The Supreme Court clarified that while the Commission could not base its decision solely on the nonexamining physician's report, it could use the report as guidance in evaluating the remaining medical evidence. The court ordered the Commission to vacate its previous order and issue a new decision based on a proper evaluation of the evidence. View "State ex rel. Heilman v. Industrial Commission" on Justia Law

The case involves a group of relators seeking a writ of mandamus to compel the Lorain County Board of Elections to place a zoning-amendment referendum on the November 5, 2024, general-election ballot. The relators had filed a referendum petition against a municipal ordinance that rezoned approximately 300 acres of property. However, the Board of Elections sustained a protest by intervening respondents, DBR Commercial Realty, L.L.C., and Kathryn Craig, and removed the referendum from the ballot, arguing that the relators failed to file a complete certified copy of the ordinance as required by R.C. 731.32.The relators initially received what they claimed were incomplete copies of the ordinance from the clerk of the Vermilion City Council. Despite knowing the copies were incomplete, they attempted to correct the deficiencies themselves by adding missing pages from the county recorder’s office. However, the copy they filed with the finance director was still missing two pages. The Board of Elections held a protest hearing and concluded that the relators did not strictly comply with R.C. 731.32, which requires a complete certified copy of the ordinance to be filed before circulating a referendum petition.The Supreme Court of Ohio reviewed the case and upheld the Board of Elections' decision. The court emphasized that R.C. 731.32 requires strict compliance, and the relators' failure to file a complete certified copy of the ordinance rendered their petition defective. The court denied the writ of mandamus, stating that the Board did not abuse its discretion or disregard applicable law in sustaining the protest and removing the referendum from the ballot. The court also denied various motions to strike evidence and for oral argument, but granted the relators' motion to amend the case caption. View "State ex rel. Brill v. Lorain Cty. Bd. of Elections" on Justia Law

The case involves the Ohio Democratic Party and two voters, Norman Wernet and Eric Duffy, who filed a mandamus action against Ohio Secretary of State Frank LaRose. They sought to compel LaRose to rescind Directive 2024-21, which requires individuals delivering absentee ballots for family members or disabled voters to complete an attestation at the board of elections and prohibits returning such ballots to a drop box. The directive aims to prevent "ballot harvesting" and ensure the integrity and security of absentee ballot delivery.Previously, the United States District Court for the Northern District of Ohio ruled in League of Women Voters of Ohio v. LaRose that certain Ohio laws limiting who can return absentee ballots for disabled voters were preempted by the federal Voting Rights Act. Following this, LaRose issued Directive 2024-21 and later Directive 2024-24 and Advisory 2024-03, which provided additional guidance but did not substantially alter the original directive.The Ohio Supreme Court reviewed the case and found that the relators' claims were barred by laches due to their unreasonable delay in filing the complaint. The court noted that the directive was issued on August 31, but the complaint was not filed until September 27, a 24-day delay. This delay was deemed unreasonable, especially given the time-sensitive nature of election-related matters. The court also found that the delay caused material prejudice to the Secretary of State and county boards of elections, as absentee voting had already begun, and changing the procedures at this stage would lead to voter confusion and administrative burdens.The Ohio Supreme Court denied the writ of mandamus based on laches and did not address the merits of the relators' claims. The court also denied the motion to intervene filed by the Republican National Committee and the Ohio Republican Party but accepted their brief as an amici curiae brief. View "State ex rel. Ohio Democratic Party v. LaRose" on Justia Law

The case involves a medical negligence claim brought by Janet Hild, the administrator of Scott Boldman's estate, against several medical professionals and entities, including Samaritan Health Partners and Good Samaritan Hospital. Boldman, who had multiple health issues, underwent an emergency appendectomy at Good Samaritan Hospital. Post-surgery, he became combative and removed his breathing tube, after which he soon died. Hild claimed that the anesthesia was improperly handled, causing Boldman's aggressive behavior and subsequent death. The hospital argued that Boldman self-extubated and suffered a cardiac arrest unrelated to the anesthesia.The case proceeded to a jury trial in the Montgomery County Court of Common Pleas. The jury found that Sandra Ward, the Certified Registered Nurse Anesthetist, was negligent in her care of Boldman. However, only the six jurors who found negligence were allowed to vote on whether Ward's negligence proximately caused Boldman's death. They concluded it did not. Hild filed a motion for a new trial, arguing that all jurors should have been allowed to vote on proximate cause. The trial court denied the motion.The Second District Court of Appeals reversed the trial court's decision in part, holding that the trial court erred by not allowing all jurors to vote on proximate cause, and remanded the case for a new trial on specific issues. The hospital appealed to the Supreme Court of Ohio.The Supreme Court of Ohio held that the same-juror rule applies in all negligence cases where the jury answers sequential interrogatories that separate the elements of negligence. This means the same three-fourths of jurors must concur on all elements for a valid verdict. The court reversed the Second District's decision to the extent it ordered a new trial and reinstated the jury's verdict in favor of the hospital. View "Hild v. Samaritan Health Partner" on Justia Law

The relator, Justin Tjaden, sought a writ of mandamus to have his name placed on the November 5, 2024, general-election ballot as an independent candidate for the office of state representative of Ohio House District 99. Tjaden's petition was found to be 124 valid signatures short of the required number. He argued that the boards of elections exceeded their authority by invalidating signatures as "not genuine" and violated his procedural due process and equal protection rights. Tjaden also contended that the statutory requirement for independent candidates to submit a petition with signatures amounting to at least one percent of registered voters who cast ballots for governor in the 2022 general election was unconstitutional.The Geauga County Board of Elections determined that Tjaden's petition contained 371 valid signatures, which was insufficient to qualify for the ballot. Tjaden attempted to challenge this decision in the Geauga County Court of Common Pleas but was unsuccessful due to procedural issues. He then filed a complaint in the same court and a mandamus action in the Supreme Court of Ohio. The Supreme Court dismissed his first mandamus action based on the jurisdictional-priority rule but allowed him to file a second mandamus action after his common-pleas-court case was removed to federal court.The Supreme Court of Ohio denied Tjaden's writ of mandamus. The court held that Tjaden did not have enough valid signatures to qualify for the ballot, even if all contested signatures were deemed valid. The court also found that Tjaden's procedural due process rights were not violated, as the mandamus action provided him with the necessary process. Additionally, the court declined to address Tjaden's equal protection claim, stating that even if the statute were declared unconstitutional, there would be no statutory requirement for an independent candidate to qualify for the ballot. Thus, the court denied the writ. View "State ex rel. Tjaden v. Geauga County Board of Elections" on Justia Law