State ex rel. Phillips v. Ohio Pub. Emps. Retirement Sys.

2025 Ohio 4557
CourtOhio Court of Appeals
DecidedSeptember 30, 2025
Docket23AP-606
StatusPublished

This text of 2025 Ohio 4557 (State ex rel. Phillips v. Ohio Pub. Emps. Retirement Sys.) 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. Phillips v. Ohio Pub. Emps. Retirement Sys., 2025 Ohio 4557 (Ohio Ct. App. 2025).

Opinion

[Cite as State ex rel. Phillips v. Ohio Pub. Emps. Retirement Sys., 2025-Ohio-4557.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

State ex rel. Julia Phillips, :

Relator, : No. 23AP-606 v. : (REGULAR CALENDAR) Ohio Public Employees Retirement : System of Ohio, : Respondent. :

DECISION

Rendered on September 30, 2025

On brief: Malyuk McDaniel Kasper, LLC, Eric McDaniel, and Matthew Kasper, for relator. Argued: Eric McDaniel.

On brief: Dave Yost, Attorney General, Henrique A. Geigel, and Lisa A. Reid, for respondent. Argued: Lisa A. Reid.

IN MANDAMUS ON OBJECTIONS TO THE MAGISTRATE’S DECISION

LELAND, J. {¶ 1} Relator, Julia Phillips, has filed an original action requesting this court issue a writ of mandamus ordering respondent, Ohio Public Employees Retirement System of Ohio (“OPERS”), to vacate its order denying disability benefits and to issue a new order granting said disability benefits. {¶ 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 who issued a decision, including findings of fact and conclusions of law, which is appended hereto. The magistrate recommends that this court deny relator’s request for a writ of mandamus. No. 23AP-606 2

{¶ 3} Relator has filed objections to the magistrate’s decision arguing the magistrate erred in (1) rendering inaccurate findings of fact, (2) denying relator’s motion for discovery, (3) failing to respond to all of relator’s arguments, (4) finding OPERS issued valid decisions, (5) finding OPERS is not required to prove it provided all documentation to its medical reviewer, and (6) finding OPERS’s decision to deny benefits was not an abuse of discretion. {¶ 4} Under Ohio law, “ ‘[m]andamus is the appropriate remedy to challenge a decision by OPERS, because there is no statutory right to appeal.’ ” Ruf v. Ohio Pub. Emps. Retirement Sys., 2021-Ohio-4389, ¶ 23 (10th Dist.), quoting State ex rel. Domhoff v. Ohio Pub. Emps. Retirement Sys. Bd., 2014-Ohio-3688, ¶ 12. In bringing such an action, relator “ ‘must establish a clear legal right to the requested relief, a clear legal duty on the part of OPERS to provide that relief, and the lack of an adequate remedy in the ordinary course of the law.’ ” Id., quoting Domhoff at ¶ 13. In order to show he or she is entitled to the requested writ, a relator “must demonstrate that OPERS abused its discretion.” Id. at ¶ 24, citing Domhoff at ¶ 14. Further, “[i]n the context of a mandamus action, OPERS abused its discretion if it entered an order that was not supported by some evidence.” Id., citing State ex rel. Powell v. Ohio Pub. Emps. Retirement Sys., 2021-Ohio-4030, ¶ 12. {¶ 5} Several of relator’s objections are interrelated and will be considered jointly. We initially address relator’s objections to the magistrate’s findings of fact Nos. 8 and 15. Specifically, relator challenges the magistrate’s findings that “OPERS sent claimant’s medical records to its third-party administrator,” and that Dr. Robert Ferguson “also indicated that he received the medical records sent to [UMass Chan Medical School aka “Commonwealth Medicine” or “CWM”] by OPERS.” (Appended Mag.’s Decision at ¶ 39.) Relator argues the Ohio Administrative Code requires OPERS to send all such documentation “to the reviewing physician, and there is no proof this occurred; only that some documentation was supplied.” (Relator’s Objs. at 9.) Similarly, relator challenges the magistrate’s findings that “OPERS forwarded the appeal documents to CWM and Dr. Ferguson for a new medical review,” and that “Dr. Ferguson noted his receipt and review of the medical records sent to CWM by OPERS.” (Appended Mag.’s Decision at ¶ 46.) According to relator, there is no statement or information by Dr. Ferguson or Dr. Maurice Mast of receiving “all evidence.” (Relator’s Objs. at 11.) In a related objection, No. 23AP-606 3

relator argues the magistrate erred in finding OPERS is not required to prove it provided all documentation to its medical reviewer. {¶ 6} The magistrate addressed relator’s contention that OPERS abused its discretion in failing to show it complied with the requirement of giving the medical reviewer “all evidence” in accordance with Adm.Code 145-2-23(C)(1). Specifically, the magistrate found relator did not “show that OPERS failed to forward all medical evidence to the medical reviewer, Dr. Ferguson, or that Dr. Ferguson did not review all relevant documentation.” (Appended Mag.’s Decision at ¶ 59.) The magistrate noted relator “fails to point to any statute or rule that requires OPERS to provide proof that it forwarded the medical record to the medical reviewer,” nor could relator point to any authority requiring the medical reviewer to “list all additional evidence received or necessarily comment on the additional evidence.” (Appended Mag.’s Decision at ¶ 59.) {¶ 7} On review, we find no error with those determinations. Adm.Code 145-2- 21(B)(3) states in part: “Upon receipt of a complete disability application . . . the retirement system’s medical consultant(s) shall review all such documentation and prepare a recommendation to the board.” Adm.Code 145-2-23(C)(1) states in part: “After submission of any additional medical evidence . . . all evidence shall be reviewed by the medical consultant(s) who shall recommend action for concurrence by the board.” {¶ 8} OPERS maintains, and we agree, neither the rule nor the statutes mandate that OPERS “affirmatively prove” transmission of medical records to Drs. Ferguson and Mast. (Respondent’s Memo in Opp. to Relator’s Objs. at 18.) Nonetheless, we note the record in this case contains a notation from CWM and its examining physician, Dr. Ferguson, indicating “Medical records sent to CWM by OPERS.” (Certified Record (“C.R.”) at 197.) Further, as noted by OPERS, Dr. Ferguson’s “Clinical Overview” provided a summary of the records he reviewed. (C.R. at 198-99.) In general, “[w]here nothing in the record indicates procedural irregularity, a presumption of regularity attaches to administrative agency proceedings.” Arnold v. Ohio Adult Parole Auth., 2011-Ohio-4928, ¶ 14 (10th Dist.), citing Freeman v. Ohio Dept. of Human Servs., 1995 Ohio App. LEXIS 5472 (10th Dist. Dec. 14, 1995), citing State ex rel. Ohio Bldg. Restoration, Inc. v. Indus. Comm., 64 Ohio St.3d 188, 189 (1992); T. Marzetti Co. v. Doyle, 37 Ohio App.3d 25, 29 (10th Dist. 1987). No. 23AP-606 4

{¶ 9} As also observed by the magistrate, “neither OPERS nor Dr. Ferguson were under any duty to list all of the evidence received or reviewed.” (Appended Mag.’s Decision at ¶ 62.) See, e.g., State ex rel. Marchiano v. School Emps. Retirement Sys., 2009-Ohio- 307, ¶ 23 (“SERS [School Employees Retirement System] has no duty to specify the evidence it relied upon and explain its reasons for denying [the appellant’s] application” for disability retirement benefits.); State ex rel. Cydrus v. Ohio Pub. Emps. Retirement Sys., 2010-Ohio-5770, ¶ 17, citing Marchiano at ¶ 23 (“the retirement board had no duty under statute or administrative rule to specify the evidence it relied upon or to explain its reasons” in terminating disability retirement benefits). Nor does due process require “a more detailed retirement board decision.” Cydrus at ¶ 25, citing State ex rel. VanCleave v. School Emps. Retirement Sys., 2008-Ohio-5377, ¶ 23 (noting “[t]his court has already rejected a similar claim that the School Employees Retirement System had a duty based on procedural due process to identify the evidence it relied upon and to briefly explain its reasons for denying disability-retirement benefits”). Id. Accordingly, “ ‘[a]lthough it may be preferable from a policy standpoint that a retirement board explain its reasoning for its decision,’ ” under Ohio’s existing statutes “there is no duty to do so.” Marchiano at ¶ 23, quoting VanCleave at ¶ 27.

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Bluebook (online)
2025 Ohio 4557, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-phillips-v-ohio-pub-emps-retirement-sys-ohioctapp-2025.