Miller v. Dept. of Job & Family Servs.

CourtOhio Court of Appeals
DecidedMay 11, 2026
Docket25AP0040
StatusPublished

This text of Miller v. Dept. of Job & Family Servs. (Miller v. Dept. of 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
Miller v. Dept. of Job & Family Servs., (Ohio Ct. App. 2026).

Opinion

[Cite as Ohio Dept. of Job and Family Servs., 2026-Ohio-1708.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF WAYNE )

BRENDA MILLER C.A. No. 25AP0040

Appellant

v. APPEAL FROM JUDGMENT ENTERED IN THE OHIO DEPARTMENT OF JOB AND COURT OF COMMON PLEAS FAMILY SERVICES COUNTY OF WAYNE, OHIO CASE No. 2024-CVC-F-000423 Appellee

DECISION AND JOURNAL ENTRY

Dated: May 11, 2026

HENSAL, Judge.

{¶1} Brenda Miller appeals a decision of the Wayne County Court of Common Pleas

that affirmed a decision of the Ohio Department of Job and Family Services (“ODJFS”) that

determined she was ineligible for Medicaid benefits. For the following reasons, this Court affirms.

I.

{¶2} Ms. Miller has an account with the State Teacher’s Retirement System (“STRS”),

which is a defined benefit employers pension plan. The account contains over $5,700. Although

Ms. Miller receives interest on the amount, she does not receive a monthly benefit payment

because she does not have enough service credits. According to Ms. Miller, when she initially

applied for Medicaid, she was told that she only had to report the interest payments as income.

{¶3} In 2024, ODJFS notified Ms. Miller that it was terminating her benefits because of

the cash-out balance of the STRS account. Ms. Miller requested a hearing, but the hearing officer

determined that the account qualified as a resource and overruled her appeal. Ms. Miller requested 2

an administrative appeal, but ODJFS affirmed the hearing officer’s decision. Ms. Miller appealed

that decision to the common pleas court, but it also concluded that the STRS account qualified as

resources and that Ms. Miller, therefore, is ineligible for benefits. Ms. Miller has appealed,

assigning two errors.

II.

ASSIGNMENT OF ERROR I

DUE IN PART TO THE COMPLEX WORDING OF A LAW WRITTEN WITHOUT SUFFICIENT CLARITY, JUDGE TIMOTHY R. VANSICKLE’S DECISION AFFIRMING ODJFS’S CATEGORIZATION OF A TRADITIONAL PENSION PLAN AS A COUNTABLE RESOURCE IS AN ERROR.

{¶4} Ms. Miller argues that the common pleas court incorrectly applied the Ohio

Administrative Code to her STRS account. She argues that the court should have determined

whether the account qualified as income before evaluating whether it counted as a resource. She

also argues that STRS defined pension benefit accounts should be treated as income. We review

questions related to the interpretation and application of an administrative code section de novo.

Howell v. Ohio Dept. of Job & Family Servs., 2009-Ohio-1510, ¶ 29 (7th Dist.).

{¶5} Rule 5160:1-3-3.10 of the Ohio Administrative Code “describes how retirement

funds are treated for the purpose of determining eligibility for medical assistance.” Admin.Code

5160:1-3-03.10(A). Subsection (D)(1) provides that a retirement fund “shall be evaluated as a

potential resource only after it is determined to not be income.” At the time of the ODJFS’s review

of Ms. Miller’s STRS account, subsection (C)(1) provided that “[a] retirement fund in which an

individual has the legal ability to receive regular guaranteed lifetime payments will be treated as a

source of unearned income rather than as a resource. A defined benefit employer pension plan is 3

an example of this type of retirement.” Former Admin.Code 5160:1-3-03.10(C)(1) (effective Aug.

1, 2016).1

{¶6} According to Ms. Miller, because her STRS account is a defined benefit employer

pension plan, it qualifies as income. She also argues that her account is the type of account from

which she could receive regular payments, even though she may not currently receive such

payments. She further argues that this Court’s analysis should focus on the general classification

of a retirement fund, not on one specific account.

{¶7} We understand Ms. Miller’s argument about the language of Rule 5160:1-3-

03.10(C)(1) but disagree with her interpretation of the rule. At the time ODJFS reviewed Ms.

Miller’s eligibility, the rule required “an individual” to have “the legal ability” to “receive regular

guaranteed lifetime payments.” Ms. Miller’s STRS account did not meet those requirements.

Because she does not have enough service credits to qualify under the terms of her plan, Ms. Miller

does not receive regular guaranteed lifetime payments. Instead, she may only convert her account

to cash. This is consistent with the classification of her account as a resource under subsection

(D). Admin.Code 5160:1-3-03.10(D)(2) (“A retirement fund is a countable resource if the

individual . . . has an ownership interest in the retirement fund and the legal ability to convert it to

cash.”).

{¶8} Upon review of the record, we conclude that the trial court correctly determined

that Ms. Miller’s STRS account is a countable resource, not income. Ms. Miller’s first assignment

of error is overruled.

1 Rule 5160:1-3-03.10(C)(1) was amended on March 1, 2026. It now provides that “[a] retirement fund in which an individual has the legal ability to receive regular, periodic payments, or guaranteed lifetime payments shall be treated as a source of unearned income.” It no longer includes a sentence about defined benefit employer pension plans. 4

ASSIGNMENT OF ERROR II

THERE WERE MULTIPLE MISTAKES MADE BY ODJFS EMPLOYEES AND THE LACK OF ACCOUNTABILITY INCLUDE BUT ARE NOT LIMITED TO DIRECTLY USING RULES FOR IRAS ONLY, FOR A DEFINED BENEFIT PENSION PLAN, UNWILLINGNESS TO USE THE CORRECT NAME OF THE ACCOUNT, AND A FAIR HEARING THAT VIOLATED THE LAW.

{¶9} In her second assignment of error Ms. Miller argues that the common pleas court

should have examined whether ODJFS’s review of her administrative appeal was valid. She

argues it was invalid because ODJFS affirmed an incorrect decision by the hearing officer and

because she was not provided enough time for cross-examination at the initial hearing. She also

argues that a transcript of the hearing was not provided and that ODJFS should not be allowed to

affirm a decision if the record is incomplete. She further argues that it is unclear whether the

individual who reviewed the hearing officer’s decision is a licensed attorney and that the decision

improperly refers to the standard for Individual Retirement Accounts. According to Ms. Miller,

the common pleas court incorrectly found that the relevant facts were not in dispute and made

findings that are irrelevant.

{¶10} ODJFS argues that this Court should decline to address some of Ms. Miller’s

arguments because she did not raise them to the common pleas court. In her reply brief, Ms. Miller

argues that she did raise the issues. Regarding whether she was provided enough time for cross-

examination, however, Ms. Miller only noted that she had argued to ODJFS that the hearing officer

did not provide enough time to ask questions of department employees. She did not raise this as

a reason that the denial of her administrative appeal was incorrect. Similarly, she did not argue to

the common pleas court that the denial of her administrative appeal should be reversed because

she was not provided a transcript, because the record was incomplete, or because of the credentials

of the individuals who reviewed her administrative appeal. We, therefore, conclude that Ms. 5

Miller has not preserved these arguments. See Karvo Cos., Inc. v. Dept. of Transp., 2019-Ohio-

4556, ¶ 32 (9th Dist.).

{¶11} The remaining arguments from Ms. Miller’s second assignment of error are

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Related

In Re Howell v. Dept. of Job, 08 Be 25 (3-27-2009)
2009 Ohio 1510 (Ohio Court of Appeals, 2009)

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