Gillett v. Cuyahoga Cty.

2024 Ohio 3014, 249 N.E.3d 819
CourtOhio Court of Appeals
DecidedAugust 8, 2024
Docket113391
StatusPublished

This text of 2024 Ohio 3014 (Gillett v. Cuyahoga Cty.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gillett v. Cuyahoga Cty., 2024 Ohio 3014, 249 N.E.3d 819 (Ohio Ct. App. 2024).

Opinion

[Cite as Gillett v. Cuyahoga Cty., 2024-Ohio-3014.] COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

RUTH GILLETT, ET AL., :

Plaintiffs-Appellants, : No. 113391 v. :

CUYAHOGA COUNTY, :

Defendant-Appellee. :

JOURNAL ENTRY AND OPINION

JUDGMENT: REVERSED AND REMANDED RELEASED AND JOURNALIZED: August 8, 2024

Civil Appeal from the Cuyahoga County Common Pleas Court Case No. CV-22-968557

Appearances:

Cohen Rosenthal & Kramer L.L.P., Joshua R. Cohen, and Ellen M. Kramer, for appellants.

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, and Matthew D. Greenwell and Matthew T. Fitzsimmons IV, Assistant Prosecuting Attorneys, for appellee.

ANITA LASTER MAYS, J.:

{¶1} Plaintiffs-appellants, Ruth Gillett, Christine Alexander, Cassandra

Robertson, Robert Staib, and DoraRae Vactor (collectively “the appellants”), appeal the trial court’s decision dismissing their equal protection claims. We

reverse the trial court’s decision and remand.

I. Facts and Procedural History

{¶2} On March 9, 2020, the Ohio Governor Mike DeWine declared a state

of emergency in response to the COVID-19 pandemic, and later, the director of the

Ohio Department of Health issued an order for government employees to stay at

home from work. Because of the pandemic, Cuyahoga County (“the county”)

expected to have a $74 million deficit for the 2020 fiscal year as a result of tax

revenue loss. On April 3, 2020, in response, the county declared a fiscal emergency

and implemented a mandatory furlough for non-bargaining county employees.

The purpose of the furlough was to cut expenses and require the employees to take

ten furlough days through March 2021, that amounted to 80 work hours.

{¶3} The appellants were county employees that were mandated to take part

in the furlough. The appellants’ employment ended in April 2021, when the

furlough ended. However, before the appellants’ departure, the county docked

each of their paychecks 80 work hours of pay. Although the county projected a

20% decrease in sales tax revenue and a 10% decrease in property tax revenue, it

overestimated the monetary deficit because sales tax revenue decreased by only

2% and no property tax revenue deficit occurred. Additionally, the county received

$215 million from the federal government in pandemic aid. Thus, the county

experienced no monetary deficit and actually increased their revenue. {¶4} On April 13, 2021, Cuyahoga Cty. Ord. 02021-0004 was enacted to give

current bargaining and non-bargaining employees who participated in the

furlough a bonus of up to 80 work hours based on their hourly pay. However,

employees who were no longer working for the county, but were mandated to

participate in the furlough, were not eligible to receive bonus pay. The county

retained the money from the former employees, thereby incurring a windfall.

{¶5} On September 12, 2022, appellants filed a complaint and then on

November 28, 2022, appellants filed an amended complaint seeking a declaratory

judgment alleging the county violated the Equal Protection Clause by failing to

provide reimbursement of pay lost by former employees pursuant to its mandatory

furlough program. The appellants brought this case as a putative class action,

representing themselves and all bargaining and non-bargaining former county

employees who were not eligible to receive the Ord. 02021-0004 bonus.

{¶6} On February 6, 2023, the appellants filed consolidated motions for

class certification and appointment of class counsel, but the trial court did not rule

on the motions. On May 3, 2023, the county filed a motion for judgment on the

pleadings. On November 13, 2023, the trial court granted judgment on the

pleadings in favor of the county. The appellants filed this appeal assigning one

error for our review:

The trial court erred in granting judgment on the pleadings to Cuyahoga County on the Equal Protection claims alleged by the appellants in their complaint. II. Standard of Review

{¶7} “‘Appellate review of a judgment on the pleadings involves only

questions of law and is therefore de novo.’” Berryhill v. Khouri, 2021-Ohio-504,

¶ 13 (8th Dist.), quoting New Riegel Local School Dist. Bd. of Edn. v. Buehrer Group

Architecture & Eng., Inc., 2019-Ohio-2851 ¶ 8, citing Rayess v. Edn. Comm. for

Foreign Med. Graduates, 2012-Ohio-5676, ¶ 18. “Motions for judgment on the

pleadings are governed by Civ.R. 12(C), which states: ‘After the pleadings are closed

but within such time as not to delay the trial, any party may move for judgment on

the pleadings.’” Id.; Civ.R. 12(C). “‘In order to be entitled to a dismissal under Civ.R.

12(C), it must appear beyond doubt that [the nonmovant] can prove no set of facts

warranting the requested relief, after construing all material factual allegations in

the complaint and all reasonable inferences therefrom in [the nonmovant’s] favor.’”

Id., quoting State ex rel. Toledo v. Lucas Cty. Bd. of Elections, 95 Ohio St.3d 73, 74

(2002). “When considering a Civ.R. 12(C) motion for judgment on the pleadings,

the court may consider the complaint, the answer, and any material attached as

exhibits to those pleadings.” Id., citing Jordan v. Giant Eagle Supermarket, 2020-

Ohio-5622, ¶ 20 (8th Dist.), citing Schmitt v. Edn. Serv. Ctr., 2012-Ohio-2210, ¶ 9

(8th Dist.).

III. Law and Analysis

{¶8} The appellants argue that the trial court erred in granting judgment on

the pleadings on their Equal Protection claims. The Equal Protection Clause of the

Fourteenth Amendment to the United States Constitution and Ohio’s Equal Protection Clause in art. I, § 2 of the Ohio Constitution “provide individuals with

equal protection under the laws and apply the same analysis to determine whether

a statutory classification violated the equal protection clauses.” State v. Jones,

2022-Ohio-1169, ¶ 40 (8th Dist.), citing State v. Aalim, 2017-Ohio-2956, ¶ 29-30.

{¶9} “‘In considering whether state legislation violates the Equal Protection

Clause of the Fourteenth Amendment . . . [courts] apply different levels of scrutiny

to different types of classifications.’” Aalim at ¶ 30, quoting Clark v. Jeter, 486

U.S. 456, 461 (1988). “We use the same analytic approach in determining whether

a statutory classification violates Article I, Section 2 of the Ohio Constitution.” Id.,

citing State v. Williams, 88 Ohio St.3d 513, 530 (2000).

{¶10} “The first step in an equal-protection analysis is to determine the

proper standard of review.” Id. at ¶ 31, citing Arbino v. Johnson & Johnson, 2007-

Ohio-6948, ¶ 64. “When legislation infringes upon a fundamental constitutional

right or the rights of a suspect class, strict scrutiny applies.” Id. “If neither a

fundamental right nor a suspect class is involved, the rational-basis test is used.”

Id.

{¶11} In our instant case, from the face of the pleadings, the trial court is to

determine if there are enough facts to ascertain if the ordinance infringes upon a

fundamental constitutional right or if the appellants are classified in a suspect

class. “A ‘suspect class’ is defined as ‘one saddled with such disabilities or

subjected to such a history of purposeful unequal treatment or relegated to such a

position of political powerlessness as to command extraordinary protection from the majoritarian political process.’” Id.

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2024 Ohio 3014, 249 N.E.3d 819, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gillett-v-cuyahoga-cty-ohioctapp-2024.