Grissom v. Ohio Dept. Job & Family Servs.

2020 Ohio 1608, 153 N.E.3d 986
CourtOhio Court of Appeals
DecidedApril 23, 2020
Docket108513
StatusPublished
Cited by2 cases

This text of 2020 Ohio 1608 (Grissom v. Ohio Dept. Job & Family Servs.) 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
Grissom v. Ohio Dept. Job & Family Servs., 2020 Ohio 1608, 153 N.E.3d 986 (Ohio Ct. App. 2020).

Opinion

[Cite as Grissom v. Ohio Dept. Job & Family Servs., 2020-Ohio-1608.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

DEBORAH MARTIN GRISSOM, ADMINISTRATOR, :

Plaintiff-Appellant, : No. 108513 v. :

OHIO DEPARTMENT OF JOB AND FAMILY SERVICES, :

Defendant-Appellee. :

JOURNAL ENTRY AND OPINION

JUDGMENT: VACATED RELEASED AND JOURNALIZED: April 23, 2020

Administrative Appeal from the Cuyahoga County Court of Common Pleas Case No. CV-17-874398

Appearances:

Amy C. Baughman, for appellant.

David Yost, Ohio Attorney General, and Rebecca L. Thomas, Assistant Attorney General, for appellee.

SEAN C. GALLAGHER, P.J.:

Deborah Martin Grissom, Administrator of the Estate of Persey

Tiggs, appeals the April 2019 dismissal of the case after a final judgment was

rendered and affirmed in the direct appeal. Tiggs v. Ohio Dept. of Job & Family Servs., 2018-Ohio-3164, 118 N.E.3d 985, ¶ 34 (8th Dist.). This case is rife with

procedural questions that must largely remain unanswered in light of the posture

of the appeal.

For an unknown reason, the cause was returned to the trial court’s

active docket following the Tiggs decision, despite the fact that Tiggs affirmed the

final judgment. The order reactivating the case was issued by the administrative

judge for the Cuyahoga County Court of Common Pleas. Neither the parties nor

the trial court provide an explanation in support of that administrative decision.

Loc.R. 15(J) of the Court of Common Pleas of Cuyahoga County, General Division,

only permits the reactivation of a case following an appellate decision that both

reverses a final judgment of the trial court and orders the case to be remanded.

The Tiggs court affirmed the final judgment issued in July 2017. The procedure

used to return the case to the trial court’s active docket appears to be inapplicable

under the circumstances. The confusion in reactivating the case may be arguably

explained by the fact that the Tiggs panel failed to resolve one of the issues in the

appeal based on a jurisdictional impediment.

Nevertheless, following the reactivation of the case to the trial

court’s docket, Tiggs passed away. The administrator of Tiggs’s estate was

substituted as the real party in interest under Civ.R. 25. Compounding the errors

to this point, the Ohio Department of Job and Family Services (the “agency”), over

the administrator’s objection, claimed that Tiggs’s death deprived the trial court of

a case and controversy and sought to have the underlying cause of action dismissed. In general, an action cannot be “dismissed” following the issuance of a

final order, and especially a final order that was affirmed in the direct appeal — the

trial court lacks jurisdiction at that point in the proceedings. State ex rel. Special

Prosecutors v. Judges, Court of Common Pleas, 55 Ohio St.2d 94, 97, 378 N.E.2d

162 (1978) (generally, a trial court loses jurisdiction to take action in a cause after

an appeal has been taken and decided). Despite the entry purportedly dismissing

the action, the final judgment issued in July 2017 was not vacated.

We are thus being asked to review a post-dispositive order that

“dismissed” a closed case. It is unclear whether that dismissal provides any relief

for the agency. The final entry issued in July 2017 disposed of all pending issues in

the case by affirming the agency’s decision regarding Tiggs’s benefits but

remanding the matter to the agency with an order to assist Tiggs in resolving his

issues if necessary. It is conceivable, in light of the fact that case was returned to

the trial court’s docket, that the agency is implying that the July 2017 judgment

entry was an interlocutory order under R.C. 2505.02.

Even if the parties had preserved this issue for review, which we

consider only for the sake of discussion, we would be unable to agree with such a

notion. The July 2017 order was expressly deemed “final” in the journalization of

the judgment. More important, in Tiggs, it was also recognized that the July 2017

order was final. Tiggs at ¶ 31 (considering whether a final order resolving an

administrative appeal could be reviewed beyond questions of law). The agency did

not appeal Tiggs, and this panel has no authority to reconsider the procedural posture of a decision entered by another panel in this district. App.R. 26(A)(2)(d)

(only a majority of the court may substitute its opinion for that of the panel). Thus,

the only issue in this appeal is whether the trial court erred by conducting further

proceedings after a final judgment was entered and affirmed in the direct appeal.

Our discussion will be accordingly limited.

Tiggs received Medicaid benefits that covered his long-term

residential care expenses in a nursing facility. Id. at ¶ 2. Sometime in 2015, Tiggs’s

Medicaid benefits were terminated because he had come into possession of a life

insurance policy with a cash value exceeding the monetary limits of the pertinent

assistance program. Id. The nursing facility was designated as Tiggs’s authorized

representative during the administrative proceedings. Id. at ¶ 4. After the agency

ruled against Tiggs, the nursing facility, on behalf of Tiggs, filed an administrative

appeal in the Cuyahoga County Common Pleas Court. See generally id. The trial

court largely affirmed the agency’s decision but modified it by requiring the agency

to assist Tiggs in resolving the life insurance policy issue if the nursing home could

not facilitate a resolution.

The primary issue in the administrative appeal was the nursing

facility’s standing to prosecute the action on behalf of Tiggs, and the secondary

issue advanced in the direct appeal in Tiggs was whether the trial court properly

modified the administrative decision. Id. The trial court’s decision was affirmed

with respect to standing in Tiggs, but the majority also concluded that it lacked

statutory jurisdiction to consider the merits of the secondary issue — concluding that there is no appellate jurisdiction to review factual questions underlying the

trial court’s decision. Id. at ¶ 34. Having affirmed the final order and not

considering the second, the Tiggs panel issued a special mandate for the trial court

to carry its judgment into execution. Id.

Following Tiggs, the trial court, in large part at the urging of the

agency, implicitly concluded that it had jurisdiction to conduct further proceedings

in light of the Tiggs decision, and further that the case must be dismissed because

Tiggs’s death eroded the live case and controversy requirement. Although the trial

court agreed with the agency’s position, the final judgment as affirmed in Tiggs has

never been vacated. Because Tiggs did not remand the case for further

proceedings, the trial court lacked jurisdiction to conduct further proceedings that

led to the dismissal entry.

It is beyond dispute that in Tiggs, a special mandate to carry the

appellate judgment into execution was issued. That mandate does not invoke the

trial court’s continuing jurisdiction to conduct further proceedings. State v. Lewis,

99 Ohio St.3d 97, 2003-Ohio-2476, 789 N.E.2d 195, ¶ 28. Under R.C. 2505.39,

consistent with App.R. 27, when an appellate court “reverses or affirms a final

order, judgment or decree of a lower court on questions of law,” the court “shall

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Bluebook (online)
2020 Ohio 1608, 153 N.E.3d 986, Counsel Stack Legal Research, https://law.counselstack.com/opinion/grissom-v-ohio-dept-job-family-servs-ohioctapp-2020.