Associated Adjusters of Ohio, Inc. v. Ohio Department of Insurance

363 N.E.2d 730, 50 Ohio St. 2d 144, 4 Ohio Op. 3d 341, 1977 Ohio LEXIS 391
CourtOhio Supreme Court
DecidedJune 8, 1977
DocketNo. 76-1086
StatusPublished
Cited by9 cases

This text of 363 N.E.2d 730 (Associated Adjusters of Ohio, Inc. v. Ohio Department of Insurance) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Associated Adjusters of Ohio, Inc. v. Ohio Department of Insurance, 363 N.E.2d 730, 50 Ohio St. 2d 144, 4 Ohio Op. 3d 341, 1977 Ohio LEXIS 391 (Ohio 1977).

Opinion

Per Curiam.

R. C. Chapter 3951 establishes the authority under which the appellee, on behalf of the state of Ohio, licenses and regulates public insurance adjusters. R. C. 3951.021 provides that no person or corporation may act as [146]*146a public insurance adjuster without first having obtained a certificate of authority to act in such capacity from the Superintendent of Insurance (superintendent). In addition, R. C. 3951.06 (D)2 directs that no certificate of authority be issued unless the applicant is a resident of this state.

Appellant, Associated Adjusters, presents several constitutional challenges to the aforementioned residency requirement. At the outset, however, appellant cites a stipulation entered into by the parties, wherein it is stated that appellant’s .application was denied because of an unwritten and unpromulgated policy within the Department of Insurance. This policy requires that in order to be eligible for a certificate all the officers and directors of a corporate applicant must be residents of Ohio.

It is appellant’s position that since R. C. 3951.07 specifies that all decisions of the superintendent are subject to the provisions of R. C. 119.01 through 119.13, and because in this instance the superintendent failed to comply with the statutory procedure for the adoption of agency rules, as set out in R. C. 119.03,3 the contested policy is invalid un[147]*147der R. C. 119.02,4 and appellant’s application was therefore unlawfully denied.

This argument must fail, however, when one views the findings of fact and conclusions of law presented by the hearing officer. Because it is undisputed that none of appellant’s officers or directors reside in Ohio, the hearing officer, was correct in basing his recommendation primarily [148]*148upon the holding in State, ex rel. Johnson & Higgins Co., v. Safford (1927), 117 Ohio St. 576.

In Safford the relator was a duly incorporated Ohio company, organized to serve as a local agent for five insurance companies. At the time, G. C. 644 provided that no license to act as an insurance agent should he issued to persons not residing in this state. Because a majority of its stock was owned by a nonresident corporate insurance broker, the Superintendent of Insurance refused to issue to relator an agency license, thereby prompting relator to bring an original action in mandamus.

In upholding the action of the superintendent, the court in Safford recognized that the course pursued by relator was merely an attempt to do by indirection what could not be accomplished by direct and legal methods. Accordingly, the court stated the following in paragraph one of the syllabus:

“In the furtherance of justice, the fiction of a corporate entity may be disregarded where the corporation is so controlled and its affairs so conducted as to make it merely an instrumentality for the purpose of evading and circumventing a state law.”

We believe that this reasoning applies with equal force to the situation present herein. It is readily apparent that the individual applicants, Shipper and Phillips, have attempted to circumvent the statutory residency requirement by incorporating their enterprise in Ohio. Therefore, on the basis of the ruling in Safford, appellant’s application for a certificate of authority was properly denied. Because the hearing officer need not have applied the unwritten departmental policy in order to reach the recommendation which he did, appellant’s first argument is rejected.

Appellant also contends that the residency requirement set forth in R. G. 3951.06(D) denies it the equal protection of the law, as guaranteed by Section 2, Article I of the Ohio Constitution and the Fourteenth Anlendment to the United States Constitution.

Traditionally, equal protection issues have been ana[149]*149lyzed by using a two-step approach. A court must first determine what burden of justification the classification thereby created must meet, by looking to the nature of the classification and the individual interests affected. Memorial Hospital v. Maricopa County (1974), 415 U. S. 250, 253. Under the usual standard, equal protection is denied only if the classification is without any reasonable basis. Lindsley v. Natural Carbonic Cas Co. (1911), 220 U. S. 61, 78; State, ex rel. Clark, v. Brown (1965), 1 Ohio St. 2d 121. If, however, the classification touches on a fundamental right, its constitutionality must be judged by the stricter standard of whether it promotes a compelling state interest. Shapiro v. Thompson (1969), 394 U. S. 618, 638.

Appellant suggests that the statutory residency requirement sub judice impairs its right of interstate travel, which right has repeatedly been recognized as a fundamental constitutional freedom.5 Shapiro v. Thompson, supra; Dunn v. Blumstein (1972), 405 U. S. 330. Appellant’s reliance upon Shapiro and its progeny is, however, misplaced.6

In Shapiro the United States Supreme Court was concerned with more than mere movement; rather, it addressed the right “to migrate, resettle, find a new job, and start a [150]*150new life.” Shapiro, at page 629. The court at page 636, explained, that “* * * [t]he residence requirement and the one-year waiting-period requirement are distinct and independent prerequisites * * *” for receipt of welfare benefits, and only the latter was held to be unconstitutional. Three years later the court, in Dunn v. Blumstein, supra, invalidated a durational residence requirement for voter registration on the basis of Shapiro, but cautioned that the decision was not intended to “* * # cast doubt on the validity of appropriately defined and uniformly applied bona fide residence requirements. ’ ’ Dunn, at page 342, fn. 13. Recently, in McCarthy v. Philadelphia Civil Service Comm. (1976), 424 U. S. 645, the court reaffirmed the validity of the important differentiation between a requirement of continuing, residency and a requirement of prior residency of a given duration.

We think it apparent that the non-durational residency requirement set out in R. C. 3951.06(D) does not penalize the right to interstate travel, since it does not mandate that the applicant for a certificate be an Ohio resident for a fixed period of time, thus depriving the applicant of the opportunity to earn a livelihood during that waiting period. Simple, bona fide residence in this state satisfies the express terms of the statute.

■Having established that no fundamental right is involved, it is clear that only a rational basis need be shown in order to meet appellant’s equal protection challenge. Lindsley v.

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363 N.E.2d 730, 50 Ohio St. 2d 144, 4 Ohio Op. 3d 341, 1977 Ohio LEXIS 391, Counsel Stack Legal Research, https://law.counselstack.com/opinion/associated-adjusters-of-ohio-inc-v-ohio-department-of-insurance-ohio-1977.