State ex rel. Fox v. Indus. Comm.

Ohio Court of Appeals·Decided July 30, 2026·No. 24AP-140·Published

Opinion

[Cite as State ex rel. Fox v. Indus. Comm., 2026-Ohio-2922.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

State ex rel. Phyllis J. Fox, :

Relator, : No. 24AP-140

v. : (REGULAR CALENDAR)

Industrial Commission of Ohio et al., :

Respondents. :

D E C I S I O N

Rendered on July 30, 2026

On brief: Dean R. Wagner, Vicent J. DeLorenzo, and Rachel K. Phipps, for relator.

On brief: [Andy Wilson], Attorney General, and Anna Isupova, for respondent, Industrial Commission of Ohio.

On brief: Brennan, Manna & Diamond, LLC, and Stephen E. Matasich, for respondent, Metallus Inc., f.k.a. TimkenSteel Corporation. ____ IN MANDAMUS ON OBJECTIONS TO THE MAGISTRATE’S DECISION DINGUS, J. {¶ 1} Relator, Phyllis J. Fox, initiated this original action requesting this court issue a writ of mandamus ordering respondent, Industrial Commission of Ohio (‘‘commission’’), to vacate its order terminating her temporary total disability (‘‘TTD’’) compensation. {¶ 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 of this court. The magistrate issued the appended decision, including findings of fact and conclusions of law. The magistrate, applying State ex rel. AutoZone Stores, Inc. v. Indus. Comm., 2024-Ohio-5519, and No. 24AP-140 2

R.C. 4123.56(F), determined that because Fox retired on November 28, 2022, as of that date, she was not working as the direct result of reasons unrelated to her injury. The magistrate reasoned that Fox’s inability to work following her retirement was not the direct result of her workplace injury because her retirement broke the causal relationship between that injury and loss of earnings. Thus, the magistrate recommends that we deny Fox’s petition for a writ of mandamus. {¶ 3} Fox and her employer, respondent, Metallus, Inc. (“Metallus”), have filed objections to the magistrate’s decision. Fox sets forth the following objections: 1. The Magistrate Erred in Concluding That R.C. 4123.56(F) Authorizes Termination of Ongoing TTD Compensation.

2. The Magistrate Erred by Misapplying the Supreme Court’s Decision in AutoZone.

3. The Magistrate Erred in Concluding That Relator’s Acceptance of Her Pension Rendered Her Not Working for Reasons Unrelated to the Allowed Injury.

4. The Magistrate Erred by Failing to Address the Meaning of the Statutory Phrase “Otherwise Qualified.”

5. The Magistrate Erred by Applying Reasoning That the Legislature Explicitly Superseded When It Enacted R.C. 4123.56(F). (Sic passim.) Conversely, Metallus presents a sole objection for our consideration: The Magistrate’s Decision Erroneously Relies Upon Arguments Of Counsel, Rather Than Evidence Of Record, To Find That Relator Did Not Waive Her Arguments In Mandamus. {¶ 4} In ruling on these objections, this court must “undertake an independent review as to the objected matters to ascertain that the magistrate has properly determined the factual issues and appropriately applied the law.” Civ.R. 53(D)(4)(d). {¶ 5} First, we address Metallus’ objection to the magistrate’s decision. Metallus contends that the magistrate erred in not finding that, for the purpose of seeking a writ of mandamus, Fox waived her arguments that R.C. 4123.56(F) is entirely inapplicable to the facts of this case, and that R.C. 4123.56(A) is the exclusive means to terminate TTD No. 24AP-140 3

compensation. As to this issue, the magistrate rejected Metallus’ contention that Fox waived the argument that only R.C. 4123.56(A) (and necessarily not R.C. 4123.56(F)) applies to termination of ongoing TTD compensation. The magistrate noted that because there is no transcript of the hearing before the commission staff hearing officer (“SHO”), the record does not show that Fox waived these issues by not raising them before the commission. Consequently, the magistrate considered these arguments in reaching his decision. Metallus argues that the magistrate’s reasoning was flawed because a party may not rely on the absence of evidence in the record to support its argument in mandamus. But it was Metallus that asserted the arguments were waived, and, therefore, Metallus had the burden of supporting this waiver claim. And the absence of a transcript of the hearing before the SHO precluded a finding that Fox did not present the purportedly waived arguments before the commission. Thus, Metallus’ waiver argument essentially required a presumption that Fox did not make certain arguments before the SHO. The magistrate properly did not presume that the arguments had been waived. Accordingly, Metallus’ sole objection is overruled. {¶ 6} Next, we address Fox’s objections. In her objections, Fox argues that the magistrate erred in misapplying R.C. 4123.56(F) and AutoZone to the facts of this case, erred in finding that her acceptance of her employer’s retirement offer rendered her not working for reasons unrelated to the allowed injury, erred in not addressing her argument that the “otherwise qualified” language in R.C. 4123.56(F) independently required the continuation of her TTD compensation, and erred in applying reasoning that the General Assembly expressly superseded in its enactment of R.C. 4123.56(F). Collectively, Fox’s objections challenge the magistrate’s conclusion that because the commission properly applied R.C. 4123.56(F) to terminate her TTD compensation, she is not entitled to the requested writ of mandamus. {¶ 7} A writ of mandamus is an extraordinary remedy that “ ‘command[s] the performance of an act which the law specifically enjoins as a duty.’ ” State ex rel. Russell v. Klatt, 2020-Ohio-875, ¶ 7, quoting R.C. 2731.01. To be entitled to a writ, Fox must establish (1) a clear legal right to the requested relief, (2) that the commission had a clear legal duty to provide such relief, and (3) she lacked an adequate remedy in the ordinary course of the law. State ex rel. Pressley v. Indus. Comm., 11 Ohio St.2d 141 (1967). A writ No. 24AP-140 4

of mandamus lies only when “there is a legal basis to compel the commission to perform its duties under the law or when the commission has abused its discretion in carrying out its duties.” State ex rel. Cassens Corp. v. Indus. Comm., 2024-Ohio-526, ¶ 10. A writ of mandamus “may issue against the Industrial Commission if the commission has incorrectly interpreted Ohio law.” State ex rel. Gassmann v. Indus. Comm., 41 Ohio St.2d 64, 65 (1975). {¶ 8} At issue in this mandamus action is the application of R.C. 4123.56, which addresses TTD compensation and states in pertinent part: (A) Payments shall continue pending the determination of the matter, however payment shall not be made for the period when any employee has returned to work, when an employee’s treating physician, certified nurse-midwife, clinical nurse specialist, or certified nurse practitioner has made a written statement that the employee is capable of returning to the employee’s former position of employment, when work within the physical capabilities of the employee is made available by the employer or another employer, or when the employee has reached the maximum medical improvement. ... (F) If an employee is unable to work or suffers a wage loss as the direct result of an impairment arising from an injury or occupational disease, the employee is entitled to receive compensation under this section, provided the employee is otherwise qualified. If an employee is not working or has suffered a wage loss as the direct result of reasons unrelated to the allowed injury or occupational disease, the employee is not eligible to receive compensation under this section. It is the intent of the general assembly to supersede any previous judicial decision that applied the doctrine of voluntary abandonment to a claim brought under this section. R.C. 4123.56(A) and (F).

Free access — add to your briefcase to read the full text and ask questions with AI

State ex rel. Fox v. Indus. Comm., (Ohio Ct. App. 2026).

State ex rel. Fox v. Indus. Comm. (State ex rel. Fox v. Indus. Comm.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Roe v. Planned Parenthood Southwest Ohio Region
2009 Ohio 2973 (Ohio Supreme Court, 2009)
State ex rel. Russell v. Klatt (Slip Opinion)
2020 Ohio 875 (Ohio Supreme Court, 2020)
State ex rel. McDonald v. Indus. Comm.
2021 Ohio 4494 (Ohio Court of Appeals, 2021)
State ex rel. Pressley v. Industrial Commission
228 N.E.2d 631 (Ohio Supreme Court, 1967)
State ex rel. Gassmann v. Industrial Commission
322 N.E.2d 660 (Ohio Supreme Court, 1975)
State ex rel. Teece v. Industrial Commission
429 N.E.2d 433 (Ohio Supreme Court, 1981)
State ex rel. Elliott v. Industrial Commission
497 N.E.2d 70 (Ohio Supreme Court, 1986)
State ex rel. Lewis v. Diamond Foundry Co.
505 N.E.2d 962 (Ohio Supreme Court, 1987)
State ex rel. AutoZone Stores, Inc. v. Indus. Comm.
2023 Ohio 633 (Ohio Court of Appeals, 2023)
State ex rel. AutoZone Stores, Inc. v. Indus. Comm.
2024 Ohio 5519 (Ohio Supreme Court, 2024)
State ex rel. Cassens Corp. v. Indus. Comm.
2024 Ohio 526 (Ohio Supreme Court, 2024)