State ex rel. Noll v. Indus. Comm.

2025 Ohio 5233
CourtOhio Court of Appeals
DecidedNovember 20, 2025
Docket24AP-242
StatusPublished

This text of 2025 Ohio 5233 (State ex rel. Noll 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. Noll v. Indus. Comm., 2025 Ohio 5233 (Ohio Ct. App. 2025).

Opinion

[Cite as State ex rel. Noll v. Indus. Comm., 2025-Ohio-5233.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

State ex rel. Thomas J. Noll, III, :

Relator, : No. 24AP-242 v. : (REGULAR CALENDAR) Industrial Commission of Ohio et al, :

Respondents. :

D E C I S I O N

Rendered on November 20, 2025

On brief: Urban Co. L.P.A., and Anthony P. Christine, for relator.

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

IN MANDAMUS ON OBJECTIONS TO THE MAGISTRATE’S DECISION

BOGGS, J.

{¶ 1} On April 10, 2024, relator Thomas J. Noll, III, filed this original action requesting a writ of mandamus ordering the respondent, Industrial Commission of Ohio (“commission”), to vacate its order finding an overpayment as the result of fraudulent conduct. {¶ 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, on June 18, 2025. The magistrate recommended this court deny Noll’s request for a writ of mandamus. {¶ 3} On July 9, 2024, Noll filed objections to the magistrate’s decision. Therefore, we must independently review the decision to ascertain whether “the magistrate has No. 24AP-242 2

properly determined the factual issues and appropriately applied the law.” Civ.R. 53(D)(4)(d). For the following reasons, we overrule Noll’s objections and adopt the magistrate’s decision. I. PROCEDURAL HISTORY AND FACTS {¶ 4} On February 20, 2019, Noll was injured in the course of and arising out of his employment with Agree Auto Sales Inc. when he slipped and fell on ice. On March 1, 2019, Noll filed for workers’ compensation benefits, and on March 6, 2019, the Bureau of Workers’ Compensation (“BWC”) allowed his claim for a sprain of unspecified site of right knee. Noll’s claim was later ultimately allowed for anterior cruciate ligament tear, right knee; other tear of medial meniscus, current injury; and substantial aggravation of pre- existing condition of right knee osteoarthritis. {¶ 5} On August 26, 2022, Noll filed a C-84 request for temporary total disability for the allowed conditions in his claim. Immediately above Noll’s signature on the C-84 request for temporary total disability was the following statement: I am not permitted to work while receiving temporary total compensation. I have answered the foregoing questions truthfully and completely. I am aware that any person who knowingly makes a false statement, misrepresentation, concealment of fact or any other act of fraud to obtain compensation as provided by BWC or who knowingly accepts compensation to which that person is not entitled is subject to felony criminal prosecution and may, under appropriate criminal provisions, be punished by a fine, imprisonment or both.

(Stip. at 50.)

{¶ 6} On October 14, 2022, Noll’s C-84 request was considered at a hearing before a BWC district hearing officer. The district hearing officer ultimately awarded temporary total disability compensation from August 1, 2022 through October 14, 2022 based on Noll’s C-84 request and a MEDCO-14 Physician’s Report of Work Ability signed by Dr. William Woods on August 23, 2022. The August 23, 2022 MEDCO-14 report had indicated that Noll was unable to perform various tasks such as squatting, climbing, bending, or reaching above his shoulder, and indicated that Noll was unable to work from July 31, 2022 through October 31, 2022. No. 24AP-242 3

{¶ 7} In a notice mailed on October 26, 2022, the BWC acknowledged payment of Noll’s temporary total disability benefits and stated that for Noll’s benefits to continue he must continue to provide MEDCO-14 reports from his physician and submit C-84 requests for temporary total compensation. The notice informed Noll that he would not continue to be entitled to temporary total benefits if he returned to any type of work. Noll continued to provide the MEDCO-14 forms and C-84 requests for temporary total compensation through July 2023. In those completed forms, Noll indicated that he was not working and had previously not worked in any capacity. {¶ 8} On June 23, 2023, the BWC Special Investigations Department was alerted that in the 4th quarter of 2022 Noll received wages from employment at an automotive warehouse at the same time he was receiving temporary total disability benefits. In an investigation report dated September 1, 2023, the BWC Special Investigations Department noted that Noll’s employment records with the automotive warehouse indicated he worked there from October 8, 2022 through December 9, 2022 as a driver. The investigation report stated that Noll had signed various documents indicating that he understood he was not entitled to temporary total disability benefits if he returned to work, and that Noll did not inform the BWC district hearing officer at the October 2022 hearing that he was currently working at the automotive warehouse. {¶ 9} On October 23, 2023, the BWC Special Investigations Department filed a C- 86 motion for overpayment from October 8, 2022 through August 1, 2023, related to Noll’s part-time employment with the automotive warehouse. {¶ 10} On December 7, 2023, the district hearing officer granted the C-86 motion, finding that Noll was overpaid compensation from October 8, 2022 to August 1, 2023. The district hearing officer found that the “Administrator has provided reliable, probative, and substantial evidence of fraud in this claim.” (Dec. 7, 2023 SHO Decision at 2.) The district hearing officer made note of Noll signing at least five C-84 requests for temporary total compensation with the intent of misleading the commission and that “[Noll] was present at [the October 14, 2022 hearing], but did not inform the District Hearing Officer that he was working at the time of that hearing.” Id. The district hearing officer rejected Noll’s argument that a finding of fraud or overpayment was not warranted for the time after he left employment with the automotive warehouse on December 9, 2022 through August 1, No. 24AP-242 4

2023. The district hearing officer found that Noll leaving employment with the automotive warehouse did not change the fraudulent nature of his C-84 requests and that Noll had misrepresented that he was incapable of any work. Id. {¶ 11} On February 5, 2024, a staff hearing officer affirmed the December 7, 2023 district hearing officer’s decision. The staff hearing officer noted that on August 2, 2023 Noll underwent a total right knee replacement for the allowed conditions in his claim and that the BWC was not challenging temporary total disability benefits paid subsequent to August 1, 2023. {¶ 12} On February 23, 2024, the commission declined a third level hearing, and on March 19, 2024, the commission denied reconsideration of the staff hearing officer’s decision. On April 10, 2024, Noll filed the present complaint and petition for a writ of mandamus ordering the commission to vacate its finding of fraud and the period of overpayment or to limit the amount of overpayment. {¶ 13} On June 18, 2025, the magistrate issued a decision recommending this court deny Noll’s petition for a writ of mandamus. The magistrate reasoned that Noll’s misrepresentations and concealment of his employment were material, and accordingly, Noll has not shown the commission abused its discretion in finding fraud and overpayment. II. OBJECTIONS TO MAGISTRATE’S DECISION {¶ 14} On July 9, 2025, Noll asserted the following objections to the magistrate’s decision: (1) The magistrate erred in finding the October 13, 2022 DHO order may have precluded no eligibility for temporary total disability.

(2) The magistrate erred in finding the relator quit his part time position due to the BWC’s investigation.

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Bluebook (online)
2025 Ohio 5233, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-noll-v-indus-comm-ohioctapp-2025.