Baltimore Ravens, Inc. v. Self-Insuring Employers Evaluation Board
Docket: No. 00-1744
Court: Ohio Supreme Court; March 26, 2002; Ohio; State Supreme Court
Appellants Ricky Bolden, Paul Farren, Mark Harper, Lee Jones, and Stacey Hairston, former professional football players for Baltimore Ravens, Inc. (formerly the Cleveland Browns), filed complaints with the Self-Insuring Division of the Bureau of Workers’ Compensation, claiming unpaid workers’ compensation benefits. The bureau validated their complaints and referred them to the Self-Insuring Employers Evaluation Board, which, after an informal hearing on March 10, 1999, determined that the Ravens had consistently failed to meet their legal obligations regarding workers’ compensation and recommended a total fine of $50,000. The Ravens appealed this decision to the Franklin County Court of Common Pleas, arguing that the board had violated R.C. 4123.352(C) by not conducting a required hearing as per the Administrative Procedure Act.
The board subsequently filed a motion to dismiss the appeal, asserting that its decision was not subject to appeal under R.C. 119.12, as it is part of the bureau, which is exempt from such provisions. The board also sought to rectify its prior order by vacating it and scheduling a new hearing. On May 27, 1999, the board stated that its earlier findings were void while scheduling a new hearing. However, the trial court denied the board's motion to dismiss on June 9, 1999, concluding that the board is not considered part of the bureau for appeal purposes. The board then held a new hearing on June 14, 1999, and issued a new order on July 8, 1999, which mirrored the March decision. The Ravens appealed this subsequent order, leading the board to again move for dismissal, which the trial court denied on September 8, 1999, for the same reasons as before. On October 6, 1999, the trial court ruled that the board's actions related to the second appeal were void and remanded the case for a proper hearing. The trial court dismissed the second appeal, and the board subsequently appealed both cases to the Court of Appeals for Franklin County.
The court of appeals upheld the trial court's judgments, concluding that the Self-Insured Employer Evaluation Board (SIEEB) operates as an independent quasi-judicial agency distinct from the Bureau of Workers' Compensation for adjudicatory matters. SIEEB possesses jurisdiction to conduct investigations, make findings, and recommend disciplinary actions, which the administrator must implement without discretion, as dictated by R.C. 4123.352(C). The appellate court determined that actions taken by SIEEB during a hearing on June 14, 1999, were ineffective since the agency loses jurisdiction to modify or vacate decisions once an appeal is filed. Consequently, the court remanded the case for a new hearing compliant with R.C. Chapter 119, due to procedural errors in the original hearings.
The case presents two main jurisdictional questions: first, whether the trial court had jurisdiction over the appeals from the board’s decisions, specifically if the board's disciplinary recommendations are subject to judicial review under R.C. 119.12; second, whether the board retained jurisdiction to address the findings of its March 10 decision while an appeal was pending. The trial court's jurisdiction is based on R.C. 119.12, which allows appeals from agency orders arising from adjudications. While the board’s March 10 decision is acknowledged as an order from an adjudication, the definition of "agency" under R.C. 119.01(A) is pivotal to this case, as it includes specific exclusions that may affect the board's status as an agency for the purposes of the statute.
The courts determined that the board, established by R.C. 4123.352, is separate from the bureau and not subject to a specific exclusion under R.C. 119.01(A). However, they did not clarify which aspect of the definition under R.C. 119.01(A) classifies the board as an agency. The analysis assumes the board qualifies as an agency unless a specific exclusion applies. The current position disagrees, asserting that the board is part of the bureau for R.C. 119.01(A) purposes. Despite indications of the board's autonomy, such as its three-member structure and the Governor's role in appointments, the overall statutory framework indicates that the board's essential character aligns closely with the bureau. Specifically, R.C. 4123.352 mandates that the bureau provides the board with necessary support and that the board operates under the direction of the Administrator of Workers’ Compensation. The statute also outlines the administrator's authority to revoke or refuse renewal of a self-insuring employer's status based on compliance failures, and it details the board's role in investigating complaints against self-insuring employers, recommending corrective actions, and enforcing penalties, including revocation of self-insuring status. The board's recommendations must be executed promptly by the administrator.
Under R.C. 4123.352, the board lacks self-sustainability and self-governance, having no authority to administer legislation, staff, or create rules. It cannot enforce recommendations, impose penalties, or take disciplinary actions against self-insurers; these powers rest solely with the administrator, who also decides the validity of complaints. The board relies on the bureau for resources and is subject to the bureau's administrative rules. The statute explicitly states that the board is part of the Bureau of Workers' Compensation for administrative purposes. The Ravens argue that this language implies the board's independence beyond administrative matters, invoking the principle of statutory interpretation that suggests the mention of one thing excludes another. However, the court notes that this principle is merely a guideline and should not override clear legislative intent. Historical case law supports that courts should interpret statutes in line with their broader purpose rather than narrowly. The Supreme Court has similarly cautioned against overly restrictive interpretations of legislative acts.
The interpretation of 'administrative purposes' in R.C. 4123.352(A) emphasizes that it aligns with the statute's primary objective of placing the board under the bureau's authority. This phrase does not limit the board's relationship with the bureau; rather, it confirms the board's affiliation with the bureau and not the Industrial Commission, which has an ex officio member serving as chairman. Consequently, the board is considered part of the bureau for R.C. 119.01(A), making its adjudications generally exempt from the Administrative Procedure Act (APA), including R.C. 119.12 regarding appeals to common pleas court.
Moreover, even if the board were deemed separate from the bureau, it would not qualify as an agency under R.C. Chapter 119 for judicial review purposes. The lower courts failed to fully analyze the board's status under the statutory definition of 'agency' and did not explore the extent to which the board may be subject to R.C. Chapter 119 as stipulated in its enabling legislation.
R.C. 4123.352(C) empowers the board to recommend disciplinary actions against self-insuring employers following a hearing as defined by Chapter 119. General Motors argues this 'hearing' includes not only the board's procedures but also the APA's judicial review. The Ravens contend this interpretation contradicts the definition of 'hearing' in R.C. 119.01(E), which refers to public hearings by agencies under procedural safeguards. However, the board maintains that while a hearing is required under R.C. Chapter 119, the statute does not imply that an appeal follows the hearing process. The legislature intended to limit the incorporation of R.C. Chapter 119 to the procedural aspects leading to the board's recommendations, without extending it to subsequent appeals, indicating that the board's actions are governed by the guidelines established at the predecisional administrative level.
R.C. Chapter 119 is not integrated into the post-adjudicatory process, as the statute mandates the administrator to quickly implement the board’s recommendations without allowing for intervening appeals. R.C. 4123.352(C) requires the board to hold a hearing under R.C. Chapter 119 prior to making disciplinary recommendations but does not apply R.C. Chapter 119 to the board for judicial review. The court has previously addressed similar legislation, such as R.C. Chapter 4112, which governs the Ohio Civil Rights Commission. Although former R.C. 4112.05(G) and (I) referenced R.C. Chapter 119, the court determined that the commission was not subject to the thirty-day record-certification requirement of R.C. 119.12 for judicial review purposes. The court noted the incongruity in interpreting the statutes, affirming that the commission's dual status reflects the General Assembly's intent. The comparison with former R.C. 4121.44 is also relevant; while former R.C. 4121.44(Q) explicitly allowed for review and appeal under R.C. Chapter 119, former R.C. 4121.44(R) did not provide such a provision, leading the court to conclude that orders under R.C. 4121.44(R) were not intended to be appealable under R.C. Chapter 119.
The federal district court in *Lexington Supermarket, Inc. v. United States Dept. of Agriculture* ruled that decisions by the Ohio Department of Health (ODH) to disqualify or suspend vendors from the Women, Infants and Children’s (WIC) Program are not subject to judicial review under Ohio Revised Code (R.C.) 119.12. The court noted that while ODH is subject to R.C. Chapter 119 for some rulemaking purposes under R.C. 3701.132, this does not extend to judicial review rights for WIC vendors. The dissent argued that previous case law did not support this interpretation, claiming that R.C. 4123.352(C) should incorporate the entirety of R.C. Chapter 119. However, the majority maintained that these statutes only partially incorporate R.C. Chapter 119 and do not allow for appeals in the context discussed. The court highlighted that express statutory provisions are required for an agency's adjudications to be appealable under R.C. Chapter 119. As a result, the trial court was determined to lack jurisdiction over the appeals from the Self-Insuring Employers Evaluation Board's decisions, leading to a reversal of the court of appeals' judgment on this matter. It was established that an administrative board loses the authority to revisit its decisions once an appeal is filed in court, unless expressly allowed by statute.
In Lorain Edn. Assn. v. Lorain City School Dist. Bd. of Edn. and related cases, it was established that a board lacks the authority to relitigate issues during the pendency of an appeal, even if the court has no subject-matter jurisdiction. Following the Ravens' appeal from the board's March 10, 1999 order, the board lost jurisdiction to vacate that order or conduct subsequent hearings, rendering those actions ineffective. The trial court correctly identified the board's postappeal actions as a nullity but overstepped by ordering the board to vacate its March 10 order and conduct a new hearing, as this involved the merits of the appeal and required jurisdiction the trial court did not possess. While the Ravens are entitled to a new hearing under R.C. Chapter 119, the appropriate remedy would be through an action in mandamus. Consequently, the court of appeals’ judgment was reversed, and the case was remanded to the trial court for proper dismissal. Moyer, C.J., Douglas, F.E. Sweeney, Pfeifer, and Lundberg Stratton, JJ. concurred, while Cook, J. dissented.
