State, Ex Rel. Dmhmr Services v. Talikka

Citations: 469 N.E.2d 888; 13 Ohio App. 3d 420; 13 Ohio B. 507; 1983 WL 6039; 1983 Ohio App. LEXIS 11431Docket: No. 9-265

Court: Ohio Court of Appeals; December 26, 1983; Ohio; State Appellate Court

SummaryOriginalCytator Case TreatmentAnalysis

EnglishEspañolSimplified EnglishEspañol Fácil

On July 9, 1976, William Thomas Baldauf was found not guilty by reason of insanity for aggravated murder and was committed indefinitely to Lima State Hospital, with release contingent on restored sanity and safety. On May 20, 1980, the State of Ohio's Department of Mental Health filed a claim against Leo J. Talikka, Baldauf's guardian, for $59,544.08 to cover care and maintenance expenses incurred from July 14, 1976, to January 31, 1980. Following Talikka's answer to the claim, the state moved for summary judgment, which was granted. Talikka appealed, raising two assignments of error: (1) the trial court erred in ruling that R.C. 5121.12 does not violate the Fourteenth Amendment and relevant Ohio constitutional provisions; and (2) the trial court erred in granting the summary judgment.

The court found the assigned errors to be without merit. R.C. 5121.12 mandates that the support of patients in state facilities, except for those transferred from correctional institutions or those under indictment or conviction, must be paid according to the statute. Talikka argued that this statute violates equal protection clauses by creating an unjust distinction between patients required to pay for their care and those exempted, particularly highlighting that individuals under indictment are presumed innocent, similar to Baldauf's status. The court clarified that legislation must apply equally within a class and that reasonable distinctions can be made. R.C. 5121.12 creates two classifications: those exempt from payment (including individuals under indictment) and those required to pay (all other patients). Talikka contended that the exemption lacks a rational basis since both classes include individuals presumed innocent.

A rational basis exists for differentiating between individuals like Baldauf and those exempt from payment for support and maintenance. Baldauf's situation parallels a civil commitment, as he has not been charged or convicted of a crime, unlike those exempted who have been convicted or committed pending trial competency. The legislature could reasonably determine that individuals committed due to criminal charges should be funded by the state. Thus, the distinction drawn by R.C. 5121.12 is justifiable and does not violate equal protection rights under the U.S. and Ohio Constitutions.

In his second assignment of error, Baldauf argues that the trial court erred in granting summary judgment to the appellee, asserting a genuine material fact issue regarding whether the state mental facility met staffing standards set by the joint commission on hospital accreditation. He contends that if the facility did not meet these standards, he could only be charged $10 per day for care, referencing a provision deleted in 1981. Baldauf claims the appellee failed to present evidence supporting its summary judgment motion regarding this material fact, thus maintaining a genuine issue.

Under Civ. R. 56(C), summary judgment can only be granted if the evidence shows no genuine issue exists and the moving party is entitled to judgment as a matter of law. Baldauf's opposition lacked evidence, relying solely on his pleading, contrary to Civ. R. 56(E), which requires specific facts to show a genuine issue. The statute R.C. 5121.04(E) states that proof of claim from the state is prima facie evidence in support collection actions. The appellee submitted a proof of claim detailing charges, while Baldauf did not provide any counter-evidence.

In State v. Book, the court determined that a properly authenticated transcript detailing charges by the state of Ohio is accepted as prima facie evidence regarding the debt owed for an inmate's support in a mental institution. Once such a transcript is admitted, it establishes a prima facie case, shifting the burden to the defendant to refute its contents. If the transcript is accepted and the defendant fails to provide evidence to challenge this prima facie case, the claims made by the plaintiff remain uncontradicted, leading to a judgment in favor of the plaintiff. In this instance, the defendant did not contest the charges for care and treatment, leaving no genuine factual dispute. Consequently, the trial court's decision to grant summary judgment for the appellee was upheld. Justices Dahling and Ford concurred.