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State ex rel. Custom Staffing, Inc. v. Indus. Comm.

Citation: 2016 Ohio 5943Docket: 15AP-830

Court: Ohio Court of Appeals; September 22, 2016; Ohio; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In this case, Custom Staffing, Inc. pursued a mandamus action against the Industrial Commission of Ohio to vacate a decision allowing a workers' compensation claim by Coy A. Seibert. Seibert had sustained a work-related injury and sought benefits. The Ohio Bureau of Workers' Compensation initially allowed his claim for a subacute lumbar sprain but denied compensation for a lumbar disc bulge due to insufficient documentation. Seibert appealed, leading to procedural complications regarding jurisdiction and order validity. A series of appeals and orders ensued, challenging the Bureau's authority to vacate or issue orders after Seibert's appeal. The Industrial Commission ultimately found the Bureau lacked jurisdiction to alter the October 15 order post-appeal. The relator's subsequent mandamus action was denied, as the court found a plain and adequate legal remedy existed through an appeal to the common pleas court, as provided by R.C. 4123.512. The court's adoption of the magistrate's decision was unchallenged, cementing the denial of the writ. This case underscores the complexities of jurisdictional authority and the necessity of pursuing statutory appeal rights in workers' compensation disputes.

Legal Issues Addressed

Adequate Remedy at Law Precluding Mandamus Relief

Application: The relator's ability to appeal to the common pleas court constitutes an adequate legal remedy, precluding relief by mandamus.

Reasoning: Relator possesses a plain and adequate remedy at law that precludes relief in mandamus, specifically the right to appeal to the common pleas court under R.C. 4123.512.

Continuing Jurisdiction under R.C. 4123.52

Application: The commission exercised continuing jurisdiction to vacate an earlier order based on a potential legal mistake.

Reasoning: The commission directed that the reconsideration request be heard to assess if the alleged legal error warranted the commission's continuing jurisdiction.

Effect of Not Objecting to Magistrate's Findings

Application: Failure to object to a magistrate's findings results in the court adopting those findings as its decision.

Reasoning: No objections were raised against the magistrate's findings. Consequently, the Court of Appeals adopted the magistrate's decision, affirming the denial of the writ.

Jurisdiction of the Bureau of Workers' Compensation

Application: The Bureau of Workers' Compensation lacked jurisdiction to vacate the October 15, 2014 order after Seibert timely appealed.

Reasoning: The commission affirmed that since Seibert had filed an appeal on October 22, 2014, the Administrator could not revoke the October 15 order.