State ex rel. Governing Bd. of Warren Cty. Edn. Serv. Ctr. v. Ohio Dept. of Edn. & Workforce

2024 Ohio 6061
CourtOhio Court of Appeals
DecidedDecember 30, 2024
DocketCA2024-06-038
StatusPublished

This text of 2024 Ohio 6061 (State ex rel. Governing Bd. of Warren Cty. Edn. Serv. Ctr. v. Ohio Dept. of Edn. & Workforce) 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. Governing Bd. of Warren Cty. Edn. Serv. Ctr. v. Ohio Dept. of Edn. & Workforce, 2024 Ohio 6061 (Ohio Ct. App. 2024).

Opinion

[Cite as State ex rel. Governing Bd. of Warren Cty. Edn. Serv. Ctr. v. Ohio Dept. of Edn. & Workforce, 2024- Ohio-6061.]

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO

WARREN COUNTY

STATE EX REL. GOVERNING : BOARD OF WARREN COUNTY CASE NO. CA2024-06-038 EDUCATIONAL SERVICE CENTER, : et al., OPINION : 12/30/2024 Appellees, :

- vs - :

: OHIO DEPARTMENT OF EDUCATION AND WORKFORCE, et al., :

Appellants. :

CIVIL APPEAL FROM WARREN COUNTY COURT OF COMMON PLEAS Case No. 24CV97061

Ennis Britton Co. LPA, and Gary T. Stedronsky and Ryan LaFlamme, for appellees.

Keating Muething & Klekamp PLL, and Bryce J. Yoder; and Dave Yost, Ohio Attorney General, and Ashley A. Barbone, Assistant Attorney General, for appellants.

M. POWELL, J.

{¶ 1} Appellants, the Ohio Department of Education and Workforce ("DEW"),

Stephen D. Dackin, and Jo Hannah Ward, appeal the decision of the Warren County Warren CA2024-06-038

Court of Common Pleas overruling their objections and adopting the magistrate's decision

denying DEW's motion to dismiss for lack of subject-matter jurisdiction.1 For the following

reasons, we affirm.

I. Factual and Procedural Background

{¶ 2} DEW oversees Ohio's implementation of the Individuals with Disabilities in

Education Act ("IDEA"), a federal law that entitles children with disabilities to a free

appropriate public education ("FAPE"). The Warren County Educational Service Center

("WCESC") is a public agency under the IDEA. Although R.C. 3323.08 places

responsibility upon city, exempted village, and local school districts to provide FAPE to

children with disabilities, WCESC is involved in the education of children with disabilities

pursuant to contract with the aforesaid school districts. R.C. 3313.843(B). City,

exempted village, and local school districts as public school districts are included within

the definition of Local Educational Agencies or "LEAs" under the IDEA.

{¶ 3} In May 2022, Disability Rights Ohio ("DRO") filed a state complaint with

DEW alleging systemic violations of the IDEA against WCESC and its associated LEAs.

DEW investigated the allegations and issued Letters of Findings and corrective action to

WCESC and the LEAs. In response, WCESC filed a verified complaint on February 20,

2024, seeking declaratory and injunctive relief and a writ of mandamus. The essence of

WCESC's complaint was that the complaint procedure of Adm.Code 3301-51-05(K)(5)

and (6) applied to a disabled child's "school district of residence," that WCESC is not a

"school district of residence" and therefore, DEW lacked legal authority to receive the

DRO's complaint against it, investigate the complaint, or issue corrective action against

1. Stephen D. Dackin is the Director of the Ohio Department of Education and Workforce, and Jo Hannah Ward is the Director of the Office for Exceptional Children at the Ohio Department of Education and Workforce. -2- Warren CA2024-06-038

WCESC.

{¶ 4} On March 6, 2024, DEW filed a motion to dismiss WCESC's complaint

pursuant to Civ.R. 12(B)(1) and Civ.R.12(B)(6). In its Civ.R.12(B)(1) motion to dismiss,

DEW asserted that the trial court lacked subject-matter jurisdiction over WCESC's

complaint because Adm.Code 3301-51-05(K)(5) and (6) conflict with the IDEA and,

therefore, are preempted by federal law. The specific conflict advanced by DEW was that

the IDEA complaint procedure applied to any "public agency, while Adm.Code 3301-51-

05(K)(5) and (6) is more circumscribed by applying only to a disabled child's 'school

district of residence.'"

{¶ 5} On April 2, 2024, the trial court's magistrate issued a decision denying

DEW's Civ.R. 12(B)(1) motion to dismiss for lack of jurisdiction. The magistrate observed

that the IDEA complaint procedures set forth in 34 C.F.R. 300.152 and 34 C.F.R. 300.153

and those set forth by Adm.Code 3301-51-05(K)(5) and (6), are "virtually identical" with

the exception that the C.F.R. uses the term "public agency" while the Adm.Code uses the

term "school district of residence." The magistrate found that there was no federal

preemption because there was no conflict between the C.F.R. and Adm.Code in the IDEA

complaint procedure.

{¶ 6} On April 16, 2024, DEW filed objections to the April 2, 2024 magistrate's

decision denying its Civ.R. 12(B)(1) motion to dismiss for lack of subject-matter

jurisdiction. On May 23, 2024, the trial court overruled DEW's objections.2 The trial court

approved the magistrate's determination that there was no federal preemption because

there was no conflict between the federal and state administrative codes in the IDEA

2. The trial court's decision refers to a magistrate's decision of April 17, 2024 (which addressed an issue unrelated to DEW's motion to dismiss), nevertheless the trial court's decision addresses the magistrate's April 2, 2024 decision. -3- Warren CA2024-06-038

complaint procedure. The trial court held

[E]ven though the IDEA uses "public agency" and the Adm.Code uses "school district of residence" it is not an actual conflict because it provides the same protection and serves the same purpose. The Adm.Code provides children with disabilities and their parents an avenue to file a Complaint directly with the agency that is obligated to provide FAPE. Therefore, since there is no actual conflict between the Adm.Code, and IDEA, the Court finds that 3301-51-05 is not preempted by the IDEA. Additionally, Plaintiff's Complaint is seeking declaratory judgment of Ohio's minimum state complaint procedures found at Adm.Code 3301-51-05(K)(5) and (6).

{¶ 7} The trial court's decision concluded by providing, "[t]here is no just reason

for delay."

{¶ 8} DEW now appeals the trial court's May 23, 2024 decision, raising one

assignment of error for our review.

II. Legal Analysis

Final Appealable Order

{¶ 9} Before addressing the merits of DEW's assignment of error we must first

determine whether the trial court's May 23, 2024 decision is a final appealable order.

WCESC asserts that it is not, arguing that it does not fall into any of the categories of final

order defined by R.C. 2505.02(B). We disagree with WCESC.

{¶ 10} A final appealable order is a jurisdictional requisite of appellate review. "It

is well-established that an order must be final before it can be reviewed by an appellate

court. If an order is not final, then an appellate court has no jurisdiction." Anglin v.

Donohoo, 2018-Ohio-4484, ¶ 12 (12th Dist.), citing Gen. Acc. Ins. Co. v. Ins. Co. of N.

Am., 44 Ohio St.3d 17, 20 (1989).

{¶ 11} "Generally, an order denying a motion to dismiss is not a final order."

Polikoff v. Adam, 67 Ohio St.3d 100, 103 (1993). This general rule applies when the

-4- Warren CA2024-06-038

motion to dismiss challenges the trial court's jurisdiction. See U.S. Bank, N.A. v.

Courthouse Crossing Acquisitions, LLC, 2017-Ohio-9232, ¶ 12 (2d Dist.). The addition

of Civ.R. 54(B) language does not change this general rule, i.e. "[t]here is no just reason

for delay." In this regard, the supreme court has observed that

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2024 Ohio 6061, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-governing-bd-of-warren-cty-edn-serv-ctr-v-ohio-dept-of-ohioctapp-2024.