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TWISM Ents., L.L.C. v. State Bd. of Registration for Professional Engineers & Surveyors

Citation: 2022 Ohio 4677Docket: 2021-1440

Court: Ohio Supreme Court; December 28, 2022; Ohio; State Supreme Court

Original Court Document: View Document

Narrative Opinion Summary

The case involves TWISM Enterprises, L.L.C.'s appeal against the Ohio Board of Registration for Professional Engineers and Surveyors, which denied TWISM's application for a certificate to provide engineering services. The crux of the dispute centers around the statutory interpretation of R.C. 4733.16(D), specifically whether a designated full-time manager responsible for engineering activities must be a W-2 employee or can be an independent contractor. The Board initially denied the application, insisting on an employment relationship for adequate control over engineering activities. The trial court reversed this decision, stating that the statute's text does not mandate an employment relationship, and ordered the Board to grant the certificate. The Supreme Court of Ohio ultimately held that statutory deference to agency interpretations is only permissible in cases of ambiguity and found no such ambiguity in R.C. 4733.16(D) regarding the employment status of the manager. As a result, the court reversed the appellate court's judgment, allowing TWISM's independent contractor to serve as a full-time manager, thus remanding the matter to the Board for further proceedings consistent with this opinion.

Legal Issues Addressed

Judicial Deference to Administrative Agency Interpretations

Application: The Supreme Court of Ohio clarified that judicial deference to administrative agency interpretations is not mandatory but permissive, applicable only in cases of statutory ambiguity.

Reasoning: The Supreme Court of Ohio clarified that judicial deference to administrative agency interpretations is not mandatory but permissive, applicable only in cases of statutory ambiguity.

Requirements for Engineering Firm Certification

Application: The court determined that TWISM met the statutory requirements for authorization to provide engineering services, as the statute does not specify an employment relationship for the designated manager.

Reasoning: TWISM was required to designate a registered professional engineer responsible for its services, and the Board had previously claimed that only full-time employees could fulfill this role.

Role of 'Full-Time Manager' and 'Responsible Charge'

Application: The court concluded that an independent contractor could serve as a full-time manager and be in 'responsible charge' of the firm's activities, challenging the Board's position that this could only apply to employees.

Reasoning: The court concluded that an independent contractor like Cooper can indeed serve as a full-time manager.

Separation of Powers and Administrative Deference

Application: The court emphasized that mandatory deference to agency interpretations is inconsistent with Ohio's separation-of-powers principles, underscoring judicial independence in statutory interpretation.

Reasoning: Ohio's separation of powers prohibits mandatory deference to agency interpretations, contrasting with federal justifications that assume legislative delegation of policy-making authority to agencies.

Statutory Interpretation of R.C. 4733.16(D)

Application: The court found no language in R.C. 4733.16(D) that prohibits independent contractors from serving as full-time managers, thus allowing for the designation of independent contractors as such.

Reasoning: The court asserted its role in determining statutory meaning and found no language in R.C. 4733.16(D) that prohibits independent contractors from serving as full-time managers.