Hennings v. State Personnel Bd. of Review

2022 Ohio 4252, 202 N.E.3d 106
CourtOhio Court of Appeals
DecidedNovember 28, 2022
Docket2022-T-0013
StatusPublished
Cited by2 cases

This text of 2022 Ohio 4252 (Hennings v. State Personnel Bd. of Review) 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
Hennings v. State Personnel Bd. of Review, 2022 Ohio 4252, 202 N.E.3d 106 (Ohio Ct. App. 2022).

Opinion

[Cite as Hennings v. State Personnel Bd. of Review, 2022-Ohio-4252.]

IN THE COURT OF APPEALS OF OHIO ELEVENTH APPELLATE DISTRICT TRUMBULL COUNTY

LANA HENNINGS, CASE NO. 2022-T-0013

Appellant, Administrative Appeal from the - vs - Court of Common Pleas

STATE PERSONNEL BOARD OF REVIEW, Trial Court No. 2021 CV 00437

TRUMBULL COUNTY MENTAL HEALTH AND RECOVERY BOARD,

Appellee.

OPINION

Decided: November 28, 2022 Judgment: Reversed and remanded

David L. Engler, Engler Law Firm, 181 Elm Road, N.E., Warren, OH 44483 (For Appellant).

Michael D. Rossi, Guarnieri and Secrest, 151 East Market Street, P.O. Box 4270, Warren, OH 44482, and Christina L. Shaynak-Diaz, 3488 Woodland Drive, Hilliard, OH 43026 (For Appellee).

MATT LYNCH, J.

{¶1} Plaintiff-appellant, Lana Hennings, appeals from the judgment of the

Trumbull County Court of Common Pleas, affirming the decision of the State Personnel

Board of Review (SPBR) dismissing the appeals relating to the abolishment of her

position as Program Coordinator as untimely filed. For the following reasons, we reverse the decision of the lower court and remand for further proceedings consistent with this

opinion.

{¶2} Hennings was employed as a Program Coordinator for the Trumbull County

Mental Health and Recovery Board (TCMHRB). On May 19, 2020, the Board held a

meeting at which budget cuts and cost reductions were discussed and it was

recommended that it eliminate the position of Program Coordinator. The Board voted to

approve administrative cost reductions. A letter was sent to the Trumbull County

Department of Human Resources on May 21, 2020, which stated that, “for reasons of

economy” and due to “reorganization for efficient operation,” the position of Program

Coordinator was “abolished.” A notice of this action was sent to Hennings on that date.

{¶3} On November 5, 2020, Hennings filed a Notice of Appeal with the SPBR,

stating that the appeal was from a notice received on October 27, 2020. No copy of a

decision from that date is included in the record but Hennings argued in subsequent filings

that the Board denied her “formal request for reinstatement” and that October 27 was the

date it “articulated its disinclination to reinstate Hennings.”

{¶4} TCMHRB filed a motion to dismiss on the grounds that the appeal was not

timely filed since Hennings had been aware of her position’s termination in May 2020. In

response, Hennings argued that the refusal to reinstate her provided a separate ground

for appeal.

{¶5} On February 26, 2021, the administrative law judge issued a Report and

Recommendation. The judge found that Hennings’ position had been abolished in May

2020 and a timely appeal should have been filed from that action rather than the October

27 denial of Hennings’ request for reinstatement since there is no provision for an

Case No. 2022-T-0013 employee to “independently request reinstatement from a layoff.” On April 13, 2021, the

SPBR issued an order in which it adopted the recommendation of the judge and ordered

that the appeals be dismissed for lack of jurisdiction.

{¶6} Hennings filed an appeal from the decision of the SPBR in the Trumbull

County Court of Common Pleas. On February 2, 2022, the court issued a Judgment Entry

affirming the decision of the SPBR since the appeal was untimely.

{¶7} On appeal, Hennings raises the following assignment of error:

{¶8} “The Trial Court Erred in Ruling That the Continuing Violation Rule did not

Apply.”

{¶9} Although not raised by the parties, there is a jurisdictional concern. A

reviewing court may “consider a challenge to the court’s subject-matter jurisdiction for the

first time on appeal, * * * either at the parties’ suggestion or sua sponte.” Lycan v.

Cleveland, 146 Ohio St.3d 29, 2016-Ohio-422, 51 N.E.3d 593, ¶ 27; State v. Noling, 136

Ohio St.3d 163, 2013-Ohio-1764, 992 N.E.2d 1095, ¶ 10 (“[s]ubject-matter jurisdiction

cannot be waived and is properly raised” sua sponte on appeal) (citation omitted). “[A]n

appellate court may sua sponte consider whether the trial court possessed the power to

entertain an action, even where the litigants themselves fail to raise the issue.” Burns v.

Daily, 114 Ohio App.3d 693, 701, 683 N.E.2d 1164 (11th Dist.1996).

{¶10} Hennings’ notice of appeal in the Trumbull County Court of Common Pleas

was filed “pursuant to” R.C. 119.12 and R.C. 2506.01. A review of these statutes

demonstrates that neither provided jurisdiction to appeal to that court. Following this

court’s request for supplemental briefing, TCMHRB agreed that this matter was not

properly filed in the Trumbull County Court of Common Pleas.

Case No. 2022-T-0013 {¶11} R.C. 2506.01(A) provides “every final order, adjudication, or decision of any

officer, tribunal, authority, board, bureau, commission, department, or other division of

any political subdivision of the state may be reviewed by the court of common pleas of

the county in which the principal office of the political subdivision is located * * *.” “[T]he

term ‘political subdivision’ does not include the state of Ohio or its agencies; therefore,

R.C. 2506.01 could not provide for appeals” from such agencies. S. Community, Inc. v.

State Emp. Relations. Bd., 38 Ohio St.3d 224, 227, 527 N.E.2d 864 (1988); Gerst v. Ohio

Dept. of Transp. 10th Dist. Franklin No. 21AP-65, 2022-Ohio-86, ¶ 8 (applying R.C.

119.12 rather than R.C. 2506.01 to an appeal from a SPBR decision since it is “not a

‘geographic or territorial division of the state’”) (citations omitted).

{¶12} Hennings also appealed pursuant to R.C. 119.12. R.C. 119.12(B) provides:

“Any party adversely affected by any order of an agency issued pursuant to any other

adjudication [apart from admission to examination and licensure under section (A)] may

appeal to the court of common pleas of Franklin county, except that appeals * * *

under division (B) of section 124.34 of the Revised Code from a decision of the state

personnel board of review * * * shall be taken to the court of common pleas of the county

in which the appointing authority is located * * *.” R.C. 124.34(B) states: “In cases of

removal or reduction in pay for disciplinary reasons, * * * the * * * employee may appeal

from the decision of the state personnel board of review or the commission, and any such

appeal shall be to the court of common pleas of the county in which the appointing

authority is located, or to the court of common pleas of Franklin county, as provided

by section 119.12 of the Revised Code.”

{¶13} Appellate courts have found that since R.C. 124.34(B) applies only to

Case No. 2022-T-0013 terminations for disciplinary reasons, other types of appeals including layoff for

nondisciplinary reasons, are governed by R.C. 119.12 and must be filed in the Franklin

County Court of Common Pleas. In Yachanin v. Cleveland Civ. Serv. Comm., 8th Dist.

Cuyahoga No. 99802, 2013-Ohio-4485, the court observed that “R.C. 124.34(B) governs

the reduction, suspension, removal, and demotion of civil service employees for

disciplinary reasons” and “[b]ecause [appellant’s] complaint relates to a lay off for non-

disciplinary reasons, [he] had no right to appeal his layoff to the Cuyahoga County

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Cite This Page — Counsel Stack

Bluebook (online)
2022 Ohio 4252, 202 N.E.3d 106, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hennings-v-state-personnel-bd-of-review-ohioctapp-2022.