Logan v. Champaign Cty. Bd. of Elections

2025 Ohio 297
CourtOhio Court of Appeals
DecidedJanuary 31, 2025
Docket2024-CA-13
StatusPublished
Cited by1 cases

This text of 2025 Ohio 297 (Logan v. Champaign Cty. Bd. of Elections) 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
Logan v. Champaign Cty. Bd. of Elections, 2025 Ohio 297 (Ohio Ct. App. 2025).

Opinion

[Cite as Logan v. Champaign Cty. Bd. of Elections, 2025-Ohio-297.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT CHAMPAIGN COUNTY

JODI L. LOGAN : : Appellant : C.A. No. 2024-CA-13 : v. : Trial Court Case No. 2023 CV 026 : CHAMPAIGN COUNTY BOARD OF : (Civil Appeal from Common Pleas ELECTIONS, ET AL. : Court) : Appellees :

...........

OPINION

Rendered on January 31, 2025

RICK L. BRUNNER, PATRICK M. QUINN, & HANNAH FARD, Attorneys for Appellant

JEFFREY A. STANKUNAS & RYAN C. SPITZER, Attorneys for Appellee

.............

LEWIS, J.

{¶ 1} Plaintiff-Appellant Jodi L. Logan appeals from the trial court’s judgment

granting Defendants-Appellees’ motion for judgment on the pleadings with respect to her

declaratory judgment and wrongful termination in violation of public policy claims.

Because we conclude that Logan failed to demonstrate that her termination was in -2-

contravention of a clear public policy, she has failed to meet the clarity element of her

wrongful termination claim. Additionally, she failed to demonstrate that there was a

justiciable controversy between the parties, as she sought neither a determination

regarding the rights, status, or other legal relations between the parties nor a

determination of a question of construction or validity arising under a constitutional

provision, statute, or rule. Accordingly, for the reasons outlined below, we affirm the

judgment of the trial court.

I. Facts and Course of Proceedings

{¶ 2} Logan formerly served as Deputy Director of the Champaign County Board

of Elections (“the Board”). In May 2022, Logan was placed on administrative leave from

her position as Deputy Director pending an investigation into allegations that she had

failed to follow established protocol within the office and had made false statements to

the Board after she reportedly raised concerns to the Ohio Secretary of State about

possible election procedure violations by certain members of the Board. In July

2022, Logan’s employment with the Board was terminated.

{¶ 3} In September 2022, Logan commenced this action in the Franklin County

Court of Common Pleas asserting claims for wrongful termination in violation of public

policy and declaratory judgment against the Board, the director of the Board, the

chairperson of the Board, and three members of the Board (collectively “the Champaign

County Defendants”), and the Secretary of State. In her complaint, Logan claimed that

she had observed certain violations of the Secretary of State’s election directives and -3-

office security requirements and additional actions and associations that created an

appearance of impropriety during early voting in April 2022. She alleged that the Board’s

Director had failed to keep a record of people who entered the Board’s offices during early

voting, met with candidates alone, and voiced support for a particular candidate in a

contested primary. She also alleged that procedures pertaining to the security and

tabulating of absentee ballots had not been followed.

{¶ 4} Logan’s allegations specifically concerned actions of the Champaign County

Defendants that purportedly violated the Secretary of State’s election directives. The

Secretary of State had issued the election directives and advisories upon which the

allegations against the Champaign County Defendants arose and was named in this

action as the chief elections officer of the state. In her complaint, Logan set forth the

following statutory provisions concerning the authority of the Secretary of State:

13. Pursuant to ORC § 3501.05(B) the Ohio Secretary of State shall issue

instructions by directives and advisories to the Champaign County Board of

Elections as to the proper methods of conducting elections to members of

Board of Elections.

14. Pursuant to ORC § 3501.05(C) the Ohio Secretary of State shall issue

rules and instructions to the Champaign County Board of Elections for the

conduct of elections.

15. Pursuant to ORC § 3501.05(N) the Ohio Secretary of State shall

investigate irregularities in elections.

16. Pursuant to ORC § 3501.053(A) the Ohio Secretary of State may issue -4-

instructions as to the proper way of conducting elections to members of

Board of Elections by permanent or temporary directives.

{¶ 5} According to Logan, pursuant to R.C. 3501.05(B) and R.C. 3501.053, the

Secretary of State issued election directive 2021-10, which mandated a bipartisan team

in election procedures and provided that the boards of elections must provide voters with

24/7 access to the secure receptacle, that the secure receptacle must be monitored 24/7,

and that at least once daily, one Republican and one Democratic member of the board or

board staff must together check, retrieve the contents, and re-lock the receptacle.

{¶ 6} The Secretary of State also issued election directive 2020-12, which outlined

security measures and provided that the board of elections must mitigate security

vulnerabilities and adopt a security policy regarding the overall security of its office. At a

minimum, each board was required to have an after-hours monitored security system to

cover the rooms used to store the voting equipment, ballots, tabulation, and voter

registration servers and to maintain restricted access, sign-in, and supervision of visitors

to areas of the board’s office that house the voting equipment, election materials,

tabulation, and voter registration servers, networks, and computers.

{¶ 7} Logan also set forth certain provisions from the ethics policy adopted by the

Secretary of State. Under the ethics policy, members and employees of the boards of

elections were to avoid actions and associations that created an appearance of

impropriety, undermined public confidence in Ohio elections officials, or interfered with

the performance of duties by Ohio elections officials. Additionally, all members and

employees of the boards of elections were required to sign a statement indicating their -5-

knowledge of and familiarity with Ohio ethics laws and the Secretary of State’s ethics

policy. Questions about the ethics policy could be addressed to the board’s legal counsel,

the county prosecuting attorney, the county elections attorney, or the Ohio Ethics

Commission. Violations of the ethics policy could be reported to the director of elections

in the Secretary of State’s office, and reports could be made anonymously by mailing a

written statement in a sealed envelope to the Secretary of State’s office to the attention

of the director of elections. According to Logan, the Board did not develop a chain of

command policy for the Director and Deputy Director but did adopt a policy related to

security in the office, which stated:

“a. Do not go into the ballot room without both a Dem & Rep

b. Always handle ballots and all election material in pairs Dem & Rep”

{¶ 8} Despite the foregoing directives and policies, Logan alleged that she had

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2025 Ohio 297, Counsel Stack Legal Research, https://law.counselstack.com/opinion/logan-v-champaign-cty-bd-of-elections-ohioctapp-2025.