State ex rel. Liberty Steel Prods., Inc. v. Indus. Comm.

2024 Ohio 2338, 245 N.E.3d 1227
CourtOhio Court of Appeals
DecidedJune 18, 2024
Docket22AP-169
StatusPublished

This text of 2024 Ohio 2338 (State ex rel. Liberty Steel Prods., Inc. 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. Liberty Steel Prods., Inc. v. Indus. Comm., 2024 Ohio 2338, 245 N.E.3d 1227 (Ohio Ct. App. 2024).

Opinion

[Cite as State ex rel. Liberty Steel Prods., Inc. v. Indus. Comm., 2024-Ohio-2338.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

State ex rel. Liberty Steel Products, Inc., :

Relator, : No. 22AP-169 v. : (REGULAR CALENDAR) Industrial Commission of Ohio et al., :

Respondents. :

D E C I S I O N

Rendered on June 18, 2024

On brief: Keating, Muething & Klekamp PLL, and Gregory J. Robinson, for relator.

On brief: Dave Yost, Attorney General, and Natalie J. Tackett, for respondent, Industrial Commission of Ohio.

On brief: Heller, Maas, Moro & Magill, Joseph A. Moro, and Patrick J. Moro, for respondent, Kenneth Yousko.

IN MANDAMUS ON OBJECTIONS TO MAGISTRATE’S DECISION AND MOTIONS TO DISMISS MENTEL, P.J.

{¶ 1} Relator, Liberty Steel Products, Inc. (“relator”), filed this original action seeking a writ of mandamus ordering respondent, the Industrial Commission of Ohio (“commission”), to vacate the November 24, 2021 Record of Proceeding finding that relator had committed a violation of a specific safety requirement (“VSSR”) and ordering it to correct the VSSR after its employee, Kenneth Yousko (“claimant”), was injured while handling a cleaning solution with ineffective safety equipment. In addition, claimant filed a motion to dismiss the action under Civ.R. 12(B)(6), arguing that relator failed to state a No. 22AP-169 2

claim in mandamus, and relator filed a motion to dismiss Chairman Jim Hughes as a party to this action. {¶ 2} Pursuant to Civ.R. 53 and Loc.R. 13(M) of the Tenth District Court of Appeals, this matter was referred to a magistrate. The magistrate recommends that we deny the request for a writ of mandamus and overrule the motions to dismiss as moot. Relator has filed the following objections to the magistrate’s decision. {¶ 3} In the first objection, relator objects to the magistrate’s conclusion that the commission did not abuse its discretion when it ordered relator to correct the VSSR. (Obj. at 1.) The commission issued the order after finding that there was no evidence that relator had corrected the violation by providing adequate protective equipment to its employees. According to relator, however, the magistrate’s conclusion “ignores the evidence presented by Relator specifically showing the new version of gloves provided to employees as a part of its Request for Rehearing,” thus rendering the corrective order “unnecessary.” Id. at 1- 2. {¶ 4} R.C. 4121.47(B) states that once a VSSR is found, “the staff hearing officer shall, in addition to any award paid to the claimant, issue an order to the employer to correct the violation within the period of time the staff hearing officer fixes.” As the magistrate noted, referring to the hearing at which the VSSR was found: “There was no evidence presented that the employer had corrected the violation by providing compliant gloves.” (Mag.’s Decision at 7.) Because the staff hearing officer (“SHO”) determined that relator had committed a VSSR, R.C. 4121.47(B) required the SHO to issue the corrective order. The magistrate’s conclusion that this order was not an abuse of discretion is correct and consistent with the statute. {¶ 5} Relator’s underlying complaint in this objection is that the commission did not grant its request for a rehearing under Ohio Adm.Code 4121-3-20(E), as a rehearing would have allowed it to present evidence to support its assertion that it had corrected the VSSR. The regulation states that when evaluating a request for rehearing, the SHO

shall review the motion for rehearing under the following criteria: (a) In order to justify a rehearing of the staff hearing officer’s order, the motion shall be accompanied by new and additional proof not previously considered and which by due diligence No. 22AP-169 3

could not be obtained prior to the prehearing conference, or prior to the merit hearing if a record hearing was held and relevant to the specific safety requirement violation. (b) A rehearing may also be indicated in exceptional cases where the order was based on an obvious mistake of fact or clear mistake of law. Ohio Adm.Code 4121-3-20(E)(1).

{¶ 6} In the request for rehearing, relator claimed that it was entitled to a rehearing and to present additional evidence because the company’s provision of new protective gloves “was not an issue raised at the hearing, and no evidence was requested. Had it been raised, representatives for [relator] would have testified that following Claimant’s injury, the Company has provided an additional option for protective gloves for its employees.” (Dec. 23, 2021 Req. for Rehearing at 1.) However, R.C. 4121.47(B) put relator on notice that “an order to the employer to correct the violation” was a possible outcome of the proceeding. It was not the responsibility of the SHO or the commission to inform relator of its potential for liability under R.C. 4121.47(B), nor was it their responsibility to advise relator as to what evidence it should present at the hearing. Relator cannot shift its burden to present an adequate defense to avoid the corrective order onto the SHO or the commission. The standard for granting a rehearing is, in part, that the additional evidence “by due diligence could not be obtained prior to the prehearing conference, or prior to the merit hearing.” Ohio Adm.Code 4121-3-20(E)(1)(a). By relator’s own admission, it knew about but did not present the evidence of the new gloves, so it was not entitled to a rehearing to present that evidence. The first objection is overruled. {¶ 7} Second, relator objects to the magistrate’s decision “to the extent that it goes beyond the Commission’s Order and substitutes its own interpretation of the evidence.” (Obj. at 3.) Relator claims that the magistrate independently determined the proper dilution ratio for the cleaning solution that injured the claimant and mischaracterized the commission’s finding when he stated that the commission “believed the dilution ratio for claimant’s cleaning purposes should be consistent with the 20-to-1 ratio used for mop-and- bucket usage.” (Mag.’s Decision at 7.) According to relator, the magistrate failed to determine if there was “evidence to support the Commission’s determination that the No. 22AP-169 4

[Materials Safety Data Sheet (“MSDS”)] recommended a specific 20-to-1 dilution ratio for the work” that resulted in the injury. (Obj. at 4.) {¶ 8} The magistrate’s characterization of the SHO’s findings was not a novel interpretation or a reweighing of evidence. In the findings of fact, the SHO quotes the portion of the testimony of the employee who ordered the cleaning solution to be diluted in water at a 3:1 ratio. The employee first insists that the 3:1 ratio was “listed in the MSDS.” (Nov. 24, 2021 Record of Proceedings (hereinafter, “Order”) at 3.) After the employee is shown the dilution ratios on the MSDS, he admits that he didn’t know the proper dilution ratio for the solution. The order then states that the SHO “finds that the three-to-one dilution ratio of the Purple Dragon compound that the Injured Worker was working with on the date of injury was many multiple times stronger than the 20 to one dilution recommended by the MSD sheet.” Id. at 5. In the conclusions of law, the SHO states that the MSDS “directs that the Purple Dragon concentrate be diluted to a ratio of at least 20 parts water to one part of product.” Id. at 6. These statements demonstrate that the minimum dilution ratio on the MSDS was the standard by which the SHO evaluated the dilution ratio that relator’s employee recommended. The minimum dilution ratio on the MSDS was 20:1, yet relator’s employee incorrectly believed the MSDS to state a 3:1 ratio. The information on the MSDS and the testimony constituted some evidence for the commission’s finding and conclusion.

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Bluebook (online)
2024 Ohio 2338, 245 N.E.3d 1227, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-liberty-steel-prods-inc-v-indus-comm-ohioctapp-2024.