State ex rel. Cincinnati v. Indus. Comm.

2023 Ohio 3638
CourtOhio Court of Appeals
DecidedOctober 5, 2023
Docket21AP-702
StatusPublished
Cited by1 cases

This text of 2023 Ohio 3638 (State ex rel. Cincinnati v. Indus. Comm.) 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
State ex rel. Cincinnati v. Indus. Comm., 2023 Ohio 3638 (Ohio Ct. App. 2023).

Opinion

[Cite as State ex rel. Cincinnati v. Indus. Comm., 2023-Ohio-3638.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

State ex rel. City of Cincinnati, :

Relator, : No. 21AP-702

v. : (REGULAR CALENDAR)

Industrial Commission of Ohio et al., :

Respondents. :

D E C I S I O N

Rendered on October 5, 2023

On brief: Dinsmore & Shohl LLP, Brian P. Perry, and Anthony V. Jagoditz, for relator. Argued: Anthony V. Jagoditz.

On brief: Dave Yost, Attorney General, and Cindy Albrecht, for respondent Industrial Commission of Ohio. Argued: Cindy Albrecht.

On brief: Connor, Kimmet & Hafenstein LLP, and Karen D. Turano, for respondent Joseph C. Conley. Argued: Karen D. Turano.

IN MANDAMUS ON OBJECTIONS TO THE MAGISTRATE’S DECISION

LUPER SCHUSTER, J. {¶ 1} Relator, City of Cincinnati (“Cincinnati”), initiated this original action requesting this court issue a writ of mandamus ordering respondent Industrial Commission of Ohio (“commission”) to vacate its order exercising continuing jurisdiction to allow the workers’ compensation claim of claimant, Joseph C. Conley, for thyroid cancer No. 21AP-702 2

and to reinstate the August 31, 2021 order of the staff hearing officer (“SHO”) denying the claim. {¶ 2} Pursuant to Civ.R. 53 and Loc.R. 13(M) of the Tenth District Court of Appeals, this court referred the matter to a magistrate. The magistrate issued the appended decision, including findings of fact and conclusions of law. The magistrate determined the commission properly exercised continuing jurisdiction when it identified a clear mistake of law in the SHO’s order because the medical evidence cited by the SHO was not legally sufficient to rebut the statutory presumption in R.C. 4123.68(X). Thus, the magistrate recommends we deny Cincinnati’s request for a writ of mandamus. {¶ 3} Cincinnati filed objections to the magistrate’s decision. Therefore, we must independently review the decision to ascertain whether “the magistrate has properly determined the factual issues and appropriately applied the law.” Civ.R. 53(D)(4)(d). Cincinnati does not challenge the magistrate’s recitation of the pertinent facts; however, Cincinnati objects to the magistrate’s conclusion that the SHO’s order contained a clear mistake of law such that the commission properly invoked its continuing jurisdiction. More specifically, Cincinnati argues the SHO’s order did not contain a clear mistake of law and that the magistrate improperly reweighed the evidence. {¶ 4} A brief summary of the factual circumstances is pertinent to our discussion. As set forth more fully in the magistrate’s decision, Conley was diagnosed with thyroid cancer while working as a firefighter for Cincinnati. Conley filed an application for workers’ compensation benefits, and a district hearing officer (“DHO”) denied the claim, finding Cincinnati had successfully rebutted the presumption in R.C. 4123.68(X)(1) that a firefighter contracted cancer in the course of and arising out of his employment. On appeal, the SHO affirmed the DHO’s order. {¶ 5} Though the commission initially refused further appeal, Conley filed a request for reconsideration based on a clear mistake of law. In a December 2, 2021 order, the commission exercised its continuing jurisdiction and found there was a clear mistake of law in the SHO’s order. Specifically, the commission found the SHO’s reliance on two reports of Dr. Rafid Kakel was insufficient to rebut the presumption under R.C. 4123.68(X)(1) that Conley’s thyroid cancer was contracted in the course of and arising out of his employment as a firefighter, because the reports did not show, by a preponderance No. 21AP-702 3

of competent scientific evidence, that exposure to the type of carcinogen alleged did not or could not have caused Conley’s thyroid cancer. Thus, the commission granted Conley’s request for reconsideration and allowed Conley’s claim for thyroid cancer. Cincinnati then initiated the instant action in mandamus. {¶ 6} To be entitled to a writ of mandamus, Cincinnati must show a clear legal right to the relief sought and that the commission has a clear legal duty to provide such relief. State ex rel. Pressley v. Indus. Comm., 11 Ohio St.2d 141 (1967). A clear legal right to a writ of mandamus exists where the relator shows that the commission abused its discretion by entering an order which is not supported by any evidence in the record. State ex rel. Elliott v. Indus. Comm., 26 Ohio St.3d 76, 78-79 (1986). But when the record contains some evidence to support the commission’s findings, there has been no abuse of discretion and mandamus is not appropriate. State ex rel. Lewis v. Diamond Foundry Co., 29 Ohio St.3d 56, 58 (1987). {¶ 7} The commission’s power to reconsider a previous decision derives from its general grant of continuing jurisdiction under R.C. 4123.52. State ex rel. Royal v. Indus. Comm., 95 Ohio St.3d 97, 99 (2002). The commission may exercise continuing jurisdiction when one of the following prerequisites is present: “(1) new and changed circumstances, (2) fraud, (3) clear mistake of fact, (4) clear mistake of law, or (5) error by an inferior tribunal.” State ex rel. Gobich v. Indus. Comm., 103 Ohio St.3d 585, 2004- Ohio-5990, ¶ 14. Here, the commission identified a purported clear mistake of law as the basis for its continuing jurisdiction. Because we agree with the commission that the SHO committed a clear mistake of law in its application of R.C. 4123.68(X), the commission did not abuse its discretion in exercising its continuing jurisdiction on that basis. {¶ 8} As the magistrate notes, R.C. 4123.68(X) sets forth a rebuttable presumption that “[c]ancer contracted by a firefighter who has been assigned to at least six years of hazardous duty as a firefighter constitutes a presumption that the cancer was contracted in the course of and arising out of that firefighter’s employment if the firefighter was exposed to” certain carcinogens. R.C. 4123.68(X)(1). As relevant here, the employer can rebut the presumption in R.C. 4123.68(X)(1) through “evidence that shows, by a preponderance of competent scientific evidence, that exposure to the type of carcinogen alleged did not or could not have caused the cancer being alleged.” R.C. 4123.68(X)(2)(b). No. 21AP-702 4

{¶ 9} We agree with the magistrate that the commission properly exercised its continuing jurisdiction based on a clear mistake of law because the medical evidence cited by the SHO was not legally sufficient to rebut the statutory presumption in R.C. 4123.68(X). Specifically, the commission found that Dr. Kakel’s reports did not find, by a preponderance of competent scientific evidence, that exposure to the type of carcinogens here did not or could not have caused Conley’s thyroid cancer. Instead, we agree with the magistrate that while Dr. Kakel’s reports contained his opinion of possible causation based on his interpretation of scientific articles, neither of the articles Dr. Kakel relied on made any direct conclusions about the exposure to the pertinent carcinogens and the causation of Conley’s thyroid cancer. Although Dr. Kakel opined that Conley’s exposure to the carcinogens may not have been the cause of Conley’s thyroid cancer, Dr. Kakel’s report did not show by a preponderance of competent scientific evidence that Conley’s exposure to the carcinogens did not or could not have caused Conley’s thyroid cancer. Thus, because Cincinnati put forth insufficient evidence to rebut the statutory presumption in R.C. 4123.68(X), the SHO’s order contained a clear mistake of law. {¶ 10} Additionally, we do not agree with Cincinnati that the magistrate improperly reweighed the evidence.

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2023 Ohio 3638, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-cincinnati-v-indus-comm-ohioctapp-2023.