Myers v. First Energy

2025 Ohio 589
CourtOhio Court of Appeals
DecidedFebruary 24, 2025
DocketCA2024-08-016
StatusPublished

This text of 2025 Ohio 589 (Myers v. First Energy) 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
Myers v. First Energy, 2025 Ohio 589 (Ohio Ct. App. 2025).

Opinion

[Cite as Myers v. First Energy, 2025-Ohio-589.]

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO

MADISON COUNTY

JOSEPH MYERS, :

Appellant, : CASE NO. CA2024-08-016

: OPINION - vs - 2/24/2025 :

FIRST ENERGY aka OHIO EDISON : COMPANY, : Appellee.

CIVIL APPEAL FROM MADISON COUNTY MUNICIPAL COURT Case No. CVI 2400359

Joseph Myers, pro se.

FirstEnergy Service Company, and Scott J. Casto; Benesch Friedlander Coplan and Aronoff, and Kari D. Hehmeyer, for appellee.

HENDRICKSON, J.

{¶ 1} Appellant, Joseph Myers, appeals the decision of the Madison County

Municipal Court, dismissing his complaint.1 For the following reasons, we affirm.

I. Factual and Procedural Background

{¶ 2} On April 24, 2024, Myers filed a small claims complaint in the Madison

1. Pursuant to Loc.R. 6(A), we sua sponte remove this appeal from the accelerated calendar for purposes of issuing this opinion. Madison CA2024-08-016

County Municipal Court against appellee, First Energy aka Ohio Edison Company

(hereinafter "Ohio Edison"), alleging he had been overcharged for his electric service for

several years.2

{¶ 3} On May 8, 2024, Ohio Edison filed a motion to dismiss Myers' complaint for

lack of subject-matter jurisdiction, arguing that disputes over electrical service rates are

under the exclusive jurisdiction of the Public Utilities Commission of Ohio ("PUCO"). The

trial court's magistrate initially denied the motion to dismiss, but during a pretrial hearing

held on May 30, 2024, the issues were discussed more fully and the trial court ordered

supplemental briefing on jurisdiction. Ohio Edison filed a memorandum of supplemental

authority on June 13, 2024.

{¶ 4} On June 20, 2024 the magistrate found that the trial court did not have

subject-matter jurisdiction and dismissed Myers' complaint. On June 28, 2024, Myers

filed objections to the magistrate's decision, and on July 18, 2024, the magistrate issued

findings of fact and conclusions of law and concluded that complaints challenging rates

charged for utility services fall within the exclusive jurisdiction of PUCO. On July 22, 2024,

the trial court overruled Myers' objections and entered a judgment consistent with the

findings of the magistrate.

{¶ 5} Myers now appeals raising four assignments of error for our review.

II. Legal Analysis

{¶ 6} For ease of discussion, we address Myers' first and third assignments of

error together.

{¶ 7} Assignment of Error No. 1:

2. Appellee was initially identified as First Energy in the trial court and the case was captioned as Joseph Myers v. First Energy. However, on appeal, appellee has identified itself as Ohio Edison Company, therefore we have modified the caption in this appeal to reflect the name of appellee.

-2- Madison CA2024-08-016

{¶ 8} THE TRIAL COURT ERRED IN DISMISSING THE PLAINTIFF'S

COMPLAINT FOR LACK OF SUBJECT MATTER JURISDICTION.

{¶ 9} Assignment of Error No. 3:

{¶ 10} THE TRIAL COURT ERRED BY DISMISSING THE PLAINTIFF'S CLAIMS

WITHOUT GRANTING LEAVE TO AMEND HIS COMPLAINT.

{¶ 11} In his first assignment of error, Myers argues that the trial court erred in

dismissing his complaint for lack of subject-matter jurisdiction because he framed his

claims against Ohio Edison as a breach of contract. In his third assignment of error,

Myers further argues that if there was some deficiency in his complaint, the trial court

erred by not granting him leave to amend his complaint and clarify the contractual nature

of his claims. We disagree with Myers. Claims alleging utility overbilling indisputably fall

within the exclusive jurisdiction of PUCO.

{¶ 12} "PUCO has exclusive jurisdiction over most matters concerning public

utilities." Allstate Ins. Co. v. Cleveland Elec. Illum. Co., 2008-Ohio-3917, ¶ 5. This

includes matters such as rates and charges, classifications, and service. Infinite Vision

USA, LLC v. Duke Energy, Inc., 2021-Ohio-1986, ¶ 21 (12th Dist.). However, trial courts

retain limited subject-matter jurisdiction over a matter that is pure common-law tort or

contract action involving utilities that are regulated by PUCO. Id. Nevertheless, merely

casting the allegations in the complaint to sound in tort or breach of contract is insufficient

to confer jurisdiction upon the trial court. DiFranco v. FirstEnergy Corp., 2012-Ohio-5445,

¶ 26. "Instead, courts must look to the substance of the allegations in the complaint to

determine the proper jurisdiction."

{¶ 13} This court conducts a de novo review of a trial court's decision on a Civ.R.

12(B)(1) motion to dismiss for lack of subject-matter jurisdiction. Infinite Vision at ¶ 20.

The Ohio Supreme Court has adopted a two-part test to determine whether PUCO has

-3- Madison CA2024-08-016

exclusive jurisdiction: (1) whether PUCO's administrative expertise is required to resolve

the issue in dispute and (2) whether the act complained of constitutes a practice normally

authorized by the utility. If the answer to either question is 'No,' the claim is not within

PUCO's exclusive jurisdiction. Here, our de novo review answers both parts of the test

'Yes,' thus PUCO has exclusive jurisdiction over Myers' complaint.

{¶ 14} PUCO's administrative expertise is required to resolve an electricity rate

dispute. "Every public utility in Ohio is required to file, for commission review and

approval, tariff schedules that detail rates, charges and classifications for every service

offered. R.C. 4905.30. And a utility must charge rates that are in accordance with tariffs

approved by, and on file with, the commission. R.C. 4905.22." Hull v. Columbia Gas of

Ohio, 2006-Ohio-3666, ¶ 15. Additionally, the offering of special or discount rates is a

practice normally engaged in by public utilities and authorized by the commission, thus

the commission is best suited to adjudicate any claims regarding the lawfulness of the

rates charged. DiFranco, ¶ 38.

{¶ 15} No matter how Myers' complaint is structured, the substance of his

allegations is that Ohio Edison has overbilled him for electricity at rates higher than those

previously agreed upon. A trial court does not abuse its discretion to deny a motion to

amend a complaint when to do so would be a vain act. Miles Mgt. Corp. v. FirstEnergy

Corp., 2005-Ohio-1496, ¶ 38 (8th Dist.) (finding that nothing would transform plaintiff's

claims into anything other than allegations about the electrical services defendants failed

to provide, and that PUCO would be best suited to determine the issues). The present

rate dispute falls squarely within the exclusive jurisdiction of PUCO. Therefore, the trial

court did not abuse its discretion by denying Myers the opportunity to amend his

complaint.

{¶ 16} Myers' first and third assignments of error are overruled.

-4- Madison CA2024-08-016

{¶ 17} Assignment of Error No. 2:

{¶ 18} THE TRIAL COURT ERRED BY FAILING TO ADDRESS PLAINTIFF'S

ALLEGATIONS OF PROSECUTORIAL MISCONDUCT AND JUDICIAL BIAS.

{¶ 19} In his second assignment of error, Myers argues that he was prejudiced by

the failure of the magistrate and trial court judge to recuse themselves from the case and

that they were biased against him based on previous encounters with Myers in entirely

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Related

DiFranco v. FirstEnergy Corp.
2012 Ohio 5445 (Ohio Supreme Court, 2012)
Jeffers v. Bumgardner
2016 Ohio 4655 (Ohio Court of Appeals, 2016)
Miles Management v. Firstenergy, Unpublished Decision (3-31-2005)
2005 Ohio 1496 (Ohio Court of Appeals, 2005)
In re Estate of Demsey
2016 Ohio 8152 (Ohio Court of Appeals, 2016)
Infinite Vision USA, L.L.C. v. Duke Energy Ohio, Inc.
2021 Ohio 1986 (Ohio Court of Appeals, 2021)
Chasteen v. Lynch
2024 Ohio 5857 (Ohio Court of Appeals, 2024)

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Bluebook (online)
2025 Ohio 589, Counsel Stack Legal Research, https://law.counselstack.com/opinion/myers-v-first-energy-ohioctapp-2025.