State ex rel. Parente v. Indus. Comm.

CourtOhio Court of Appeals
DecidedJuly 14, 2026
Docket24AP-652
StatusPublished

This text of State ex rel. Parente v. Indus. Comm. (State ex rel. Parente 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. Parente v. Indus. Comm., (Ohio Ct. App. 2026).

Opinion

[Cite as State ex rel. Parente v. Indus. Comm., 2026-Ohio-2692.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

State ex rel. Joseph Parente, :

Relator, : No. 24AP-652

v. : (REGULAR CALENDAR)

Industrial Commission of Ohio et al., :

Respondents. :

D E C I S I O N

Rendered on July 14, 2026

On brief: Shapiro, Marnecheck & Palnik, Matthew Palnik, and Colter McArdle, for relator.

On brief: [Andy Wilson], Attorney General, and Daniel G. Schumick, for respondent Industrial Commission of Ohio.

IN MANDAMUS ON OBJECTIONS TO THE MAGISTRATE’S DECISION

EDELSTEIN, J.

{¶ 1} Relator, Joseph Parente, initiated this original action requesting this court issue a writ of mandamus ordering respondent, Industrial Commission of Ohio (“commission”), to vacate its order denying Mr. Parente’s motion requesting his average weekly wage (“AWW”) be set at $2,582.73 and to enter an order setting his AWW at that amount. {¶ 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. The magistrate issued the appended decision, including findings of fact and conclusions of law. The magistrate determined Mr. Parente No. 24AP-652 2

did not have a clear legal right to have his AWW set at $2,582.73 and the commission did not have a clear legal duty to set Mr. Parente’s AWW at that amount. Thus, the magistrate recommends we deny Mr. Parente’s petition for a writ of mandamus. {¶ 3} Mr. Parente filed objections to the magistrate’s decision. Therefore, we must independently review the decision to ascertain whether “the magistrate has properly determined the factual issues and appropriately applied the law.” Civ.R. 53(D)(4)(d). I. Background

{¶ 4} As set forth more fully in the magistrate’s decision, Mr. Parente is the owner and sole employee of Parente Homes, Inc. (“employer”), an “S” corporation, or “pass- through” entity. As the owner and employee of the employer, Mr. Parente pays himself a yearly salary, reported on a W-21, and he receives a share of the corporation’s income, losses, deductions, and credits, reported on a Schedule K-12. {¶ 5} Mr. Parente sustained a workplace injury on June 3, 2021, and the Ohio Bureau of Workers’ Compensation (“BWC”) allowed his claim. The BWC initially calculated Mr. Parente’s AWW as $765.53, based solely on his W-2 earnings. {¶ 6} On January 4, 2022, Mr. Parente filed a motion seeking to have his AWW set at $2,582.73. Mr. Parente argued both his W-2 income and his Schedule K-1 earnings should be considered to determine his AWW. In a February 19, 2022 order, a district hearing officer (“DHO”) granted Mr. Parente’s motion and adjusted his AWW to $1,969.68 based on both his W-2 and Schedule K-1 earnings. The BWC appealed the DHO’s decision and, on March 30, 2022, a staff hearing officer (“SHO”) issued an order denying relator’s motion to adjust his AWW to include his Schedule K-1 earnings. The SHO relied on a BWC policy that directs the BWC to exclude certain types of earnings in the calculation of wages.

1 The Internal Revenue Service directs that an “employer engaged in a trade or business who pays remuneration . . . for services performed by an employee” files a Form W-2 for each employee for whom “[i]ncome, Social Security, or Medicare tax was withheld,” or “[i]ncome tax would have been withheld if the employee had claimed no more than one withholding allowance or had not claimed exemption from withholding.” Internal Revenue Service, About Form W-2, Wage and Tax Statement, https://www.irs.gov/forms-pubs/about-form-w-2 (accessed July 13, 2026).

2 The Internal Revenue Service further directs that an S corporation must “file[] a copy of [the Schedule K-1

(Form 1120-S)] with the IRS to report [an individual’s] share of the corporation’s income, deductions, credits, etc.” Internal Revenue Service, About Form 1120-S, U.S. Income Tax Return for an S Corporation, https://www.irs.gov/forms-pubs/about-form-1120-s (accessed July 13, 2026). No. 24AP-652 3

Therefore, the SHO excluded Mr. Parente’s K-1 earnings and set Mr. Parente’s AWW at $1,132.40 based on his W-2 salary. Mr. Parente appealed the SHO’s March 30, 2022 order, and the commission refused Mr. Parente’s appeal. Mr. Parente then filed the instant complaint for a writ of mandamus. {¶ 7} As referenced above, the magistrate determined Mr. Parente failed to show a clear legal right to have his Schedule K-1 earnings included in the calculation of his AWW or that the commission has a clear legal duty to calculate his AWW to include his Schedule K-1 earnings. (Appended Mag.’s Decision at ¶ 38.) The magistrate noted the commission, in calculating Mr. Parente’s AWW, relied on BWC Administrator Policy #CP-23-01(IV)(C) directing that income reported on a Schedule E form is excluded from the wage calculation. Because the employer issues a Schedule K-1 to report Mr. Parente’s share of income or losses and Mr. Parente then uses his Schedule K-1 to report his income or losses on the Schedule E, the magistrate concluded this situation fell within the BWC policy excluding income from S corporations reported on a Schedule E in the calculation of wages. (Appended Mag.’s Decision at ¶ 38.) The commission expressly stated it relied on the BWC policy when it decided not to include Mr. Parente’s Schedule K-1 earnings in the calculation of his AWW. Thus, the magistrate found the commission did not abuse its discretion in relying on the BWC policy and determining Mr. Parente’s AWW in accordance with the policy. (Appended Mag.’s Decision at ¶ 41.) Although Mr. Parente argued the BWC policy was not binding, the magistrate found Mr. Parente did not demonstrate the commission had a clear legal duty to include the Schedule K-1 income as wages for purposes of calculating his AWW. (Appended Mag.’s Decision at ¶ 39-41.) {¶ 8} Mr. Parente filed an objection to the magistrate’s decision. Mr. Parente does not challenge the magistrate’s recitation of the pertinent facts; however, Mr. Parente objects to the magistrate’s conclusion that he did not have a clear legal right to have his Schedule K-1 earnings considered in the calculation of his AWW or that the commission did not have a clear legal duty to include the Schedule K-1 earnings in the AWW. II. Law and Analysis

{¶ 9} To be entitled to a writ of mandamus, Mr. Parente must demonstrate a clear legal right to the relief sought, that the commission has a clear legal duty to provide such No. 24AP-652 4

relief, and that there is no adequate remedy in the ordinary course of law. State ex rel. Pressley v. Indus. Comm., 11 Ohio St.2d 141, 162-63 (1967). Mandamus may lie if the commission abused its discretion by entering an order unsupported by evidence in the record or if there is a legal basis to compel the commission to perform its duties in accordance with law. State ex rel. Cassens Corp. v. Indus. Comm., 2024-Ohio-526, ¶ 10. If some evidence exists in the record to support the commission’s findings, this court may not “second-guess the commission’s evaluation of the evidence.” State ex rel. Black v. Indus. Comm., 2013-Ohio-4550, ¶ 22. With respect to legal questions, a writ of mandamus may issue against the commission “ ‘if the commission has incorrectly interpreted Ohio law.’ ” Cassens at ¶ 10, quoting State ex rel. Gassmann v. Indus. Comm., 41 Ohio St.2d 64, 65 (1975). {¶ 10} In his sole objection to the magistrate’s decision, Mr. Parente argues the magistrate erred in finding he does not have a clear legal right to have his Schedule K-1 earnings considered in the calculation of his AWW. R.C. 4123.61 governs the calculation of AWW and provides, in pertinent part: [T]he claimant’s . . .

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Bluebook (online)
State ex rel. Parente v. Indus. Comm., Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-parente-v-indus-comm-ohioctapp-2026.