State ex rel. McCartney v. Simco Mgt., Inc.

2025 Ohio 753
CourtOhio Court of Appeals
DecidedMarch 6, 2025
Docket24AP-13
StatusPublished

This text of 2025 Ohio 753 (State ex rel. McCartney v. Simco Mgt., Inc.) 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. McCartney v. Simco Mgt., Inc., 2025 Ohio 753 (Ohio Ct. App. 2025).

Opinion

[Cite as State ex rel. McCartney v. Simco Mgt., Inc., 2025-Ohio-753.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

State ex rel. David McCartney, :

Relator, : No. 24AP-13

v. : (REGULAR CALENDAR)

Simco Management, Inc. et al., :

Respondents. :

D E C I S I O N

Rendered on March 6, 2025

On brief: Schiavoni, Schiavoni, Bush & Muldowney, and Shawn R. Muldowney, for relator.

On brief: Dave Yost, Attorney General, and Daniel G. Schumick, for respondent Industrial Commission of Ohio.

IN MANDAMUS ON OBJECTION TO THE MAGISTRATE’S DECISION JAMISON, P.J. {¶ 1} Relator, David McCartney, has filed a mandamus action against respondents, Industrial Commission of Ohio (“commission”) and Simco Management, Inc. (“Simco”). McCartney requests this court issue a writ of mandamus ordering the commission to vacate its October 28, 2023 order denying McCartney permanent total disability (“PTD”) compensation and to issue a new order granting that compensation. Alternatively, McCartney requests this court issue a writ of mandamus ordering the commission to vacate the October 28, 2023 order and to conduct further proceedings on McCartney’s February 28, 2023 application for PTD compensation. {¶ 2} Pursuant to Civ.R. 53 and Loc.R. 13(M) of the Tenth District Court of Appeals, this court referred this matter to a magistrate. The magistrate issued the appended No. 24AP-13 2

decision, including findings of fact and conclusions of law, recommending that this court deny the requested writ of mandamus. The magistrate determined that McCartney failed to show that a commission staff hearing officer (“SHO”) erred in concluding that McCartney did not demonstrate new and changed circumstances that would justify the consideration of his February 28, 2023 application for PTD compensation. Pursuant to Civ.R. 53, McCartney objected to the magistrate’s decision, asserting that “[t]he Magistrate erred in finding that the Ohio Industrial Commission correctly found there was no evidence of new and changed circumstances since the Relator was last denied permanent total disability on August [20], 2016.” (Relator’s Obj. to the Mag. Decision at 4.) We must independently review the magistrate’s decision to ascertain if “the magistrate has properly determined the factual issues and appropriately applied the law.” Civ.R. 53(D)(4)(d). {¶ 3} To be entitled to a writ of mandamus, a relator must show by clear and convincing evidence that he has a clear legal right to the requested relief, the commission has a clear legal duty to provide that relief, and there is no adequate remedy in the ordinary course of law. State ex rel. Ohio State Univ. v. Pratt, 2022-Ohio-4111, ¶ 11. A court may issue a writ of mandamus 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. Prinkey v. Emerine’s Towing, Inc., 2024-Ohio-5713, ¶ 15. Additionally, “ ‘[a] mandatory writ may issue against the Industrial Commission if the commission has incorrectly interpreted Ohio law.’ ” State ex rel. Cassens Corp. v. Indus. Comm., 2024-Ohio-526, ¶ 10, quoting State ex rel. Gassmann v. Indus. Comm., 41 Ohio St.2d 64, 65 (1975). {¶ 4} As the magistrate recounts in his findings of fact, McCartney was injured in the course of and arising out of his employment with Simco. The commission allowed McCartney’s claim for multiple conditions, including dysthymic disorder, and awarded him permanent partial disability compensation. McCartney then applied for PTD compensation, which the commission denied in a decision issued February 15, 2008. In that decision, the SHO determined that McCartney retained the ability to perform sedentary and light work and, consequently, he did not establish by a preponderance of the evidence that he was unable to engage in sustained remunerative employment. The commission denied McCartney PTD compensation for a second time in its August 20, 2016 No. 24AP-13 3

decision. There, the SHO found that McCartney had voluntarily abandoned the workforce when he left the workforce for reasons other than the allowances in his claim. {¶ 5} This action concerns McCartney’s third application for PTD compensation, filed February 28, 2023. After the denial of McCartney’s second application and prior to the submittal of his third application, the General Assembly amended R.C. 4123.58 to add a division G, which states: If the industrial commission has adjudicated a claimant’s application for compensation payable under this section for permanent total disability and issued a final order denying compensation for that application, the claimant shall present evidence of new and changed circumstances before the industrial commission may consider a subsequent application filed by the claimant for compensation under this section for the same injury or occupational disease identified in the previous application. R.C. 4123.58(G). {¶ 6} Thus, the SHO reviewing McCartney’s third PTD application focused on whether McCartney demonstrated any new and changed circumstances as required under R.C. 4123.58(G). The SHO relied on State ex rel. Akron Paint & Varnish, Inc. v. Gullotta, 2012-Ohio-542, to conclude that McCartney did not meet his burden. {¶ 7} In Akron Paint & Varnish, the commission had previously denied a claimant temporary total disability (“TTD”) compensation because the claimant had refused his employer’s offer of a light-duty job. Id. at ¶ 6. The claimant, however, filed a new request for TTD compensation when his claim was allowed for an additional medical condition. Id. at ¶ 7. The commission exercised its continuing jurisdiction over the new request because it found evidence of new and changed circumstances based on the claimant’s worsening medical condition. Id. at ¶ 8, 15. {¶ 8} The Supreme Court of Ohio found the commission abused its discretion in exercising its continuing jurisdiction. Id. at ¶ 21. The Supreme Court held that when a claimant files a new request for TTD compensation, he is required to present evidence of new and changed circumstances that affects the grounds on which the commission previously denied the claimant compensation. Id. at ¶ 17-21. Because “the previous order denying TTD was not based on medical evidence but rather on the statutory bar of No. 24AP-13 4

compensation when a claimant unjustifiably refuses light-duty work,” the claimant had to show new and changed circumstances tending to show his employment—not medical— situation had changed. Id. at ¶ 17-18. {¶ 9} Like the claimant in Akron Paint & Varnish, McCartney was previously denied workers’ compensation benefits based on a statutory bar to compensation. In McCartney’s case, that statutory bar was the doctrine of voluntary abandonment. Consequently, relying on Akron Paint & Varnish, the SHO held: [U]nder the holding in Akron Paint & Varnish, the mere finding of medical “new and changed circumstances,” could not overcome the previous finding of a legal basis for the denial of Permanent Total Disability Compensation benefits. In other words, in accordance with the reasoning in Akron Paint & Varnish, in order to establish legal “new and changed circumstances,” [McCartney] would need to demonstrate a return to the workforce, followed by a disability which removed [] him from employment, independently attributed to the conditions recognized in this claim. (Emphasis in original.) (Stip. at 11-12.) {¶ 10} The magistrate found the SHO neither erred in applying Akron Paint & Varnish to this case nor in concluding there are no new and changed circumstances justifying the commission’s exercise of its continuing jurisdiction. We agree with the SHO and the magistrate that Akron Paint & Varnish, although interpreting the phrase “new and changed circumstances” in the context of TTD compensation, applies to this case.

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Bluebook (online)
2025 Ohio 753, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-mccartney-v-simco-mgt-inc-ohioctapp-2025.