State ex rel. Thelen v. State Emp. Relations Bd.

2025 Ohio 2239
CourtOhio Court of Appeals
DecidedJune 26, 2025
Docket24AP-283
StatusPublished

This text of 2025 Ohio 2239 (State ex rel. Thelen v. State Emp. Relations Bd.) 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. Thelen v. State Emp. Relations Bd., 2025 Ohio 2239 (Ohio Ct. App. 2025).

Opinion

[Cite as State ex rel. Thelen v. State Emp. Relations Bd., 2025-Ohio-2239.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

State ex rel. Ryan Thelen, :

Relator-Appellant, : No. 24AP-283 v. : (C.P.C. No. 23CV-4999)

State Employment Relations Board, : (REGULAR CALENDAR)

Respondent-Appellee. :

D E C I S I O N

Rendered on June 26, 2025

On brief: Ryan Thelen, pro se. Argued: Ryan Thelen.

On brief: Dave Yost, Attorney General, and Sherry M. Phillips, for appellee. Argued: Sherry M. Phillips.

APPEAL from the Franklin County Court of Common Pleas

LELAND, J. {¶ 1} Relator-appellant, Ryan Thelen, appeals from a judgment of the Franklin County Court of Common Pleas denying his request for a writ of mandamus ordering respondent-appellee, State Employment Relations Board (“SERB”), to find probable cause to believe an unfair labor practice occurred. I. Facts and Procedural History {¶ 2} The following background facts are taken primarily from the trial court’s decision denying appellant’s request for a writ, as well as from the record of proceedings. Appellant is a member of the “Cincinnati Federation of Teachers Union” (“union”); the union is “the exclusive bargaining representative for a bargaining unit of employees comprised of teachers employed with the Cincinnati Public School District” (“district”). No. 24AP-283 2

(Apr. 23, 2024 Decision at 1.) The union and district entered into a collective bargaining agreement (“CBA”) providing for “binding arbitration of grievances.” (Decision at 1.) {¶ 3} During the 2017-2018 school year, appellant was a “full-time history teacher at Dater High School within the District.” (Decision at 2.) In February 2018, appellant applied for a part-time seventh grade social studies position at Walnut Hills High School (“Walnut Hills”). The interview committee was comprised of “five teachers, and the principal’s designee, Assistant Principal Joseph Stewart.” (Decision at 2.) Appellant was not selected for the seventh grade position. According to the CBA, “the selection of a candidate for hire requires the agreement of the principal’s designee (Mr. Stewart) and a majority of the teachers on the interview committee.” (Decision at 2.) {¶ 4} On April 4, 2018, appellant filed, through the union, a grievance with the district “regarding its failure to hire him for the Seventh Grade Position.” (Decision at 2.) While the grievance was in process, but before it went to arbitration, “the Seventh Grade Position was converted to a full-time position and the District hired another teacher for the Seventh Grade Position.” (Decision at 2.) In addition, a full-time eighth grade social studies teaching position at Walnut Hills became available over the summer, and the union requested that the district place appellant “in the newly vacant Eighth Grade Position as a compromise to resolve [appellant’s] grievance, but the District refused and ultimately hired another teacher for the Eighth Grade Position.” (Decision at 2.) {¶ 5} On August 23, 2018, arbitration was held on appellant’s grievance regarding the seventh grade position, and the arbitrator awarded appellant a part-time social studies position at Walnut Hills; the award “did not specify that a specific position was to be awarded, just that a part-time social studies position at the specified school was to be awarded.” (Decision at 3.) On September 4, 2018, appellant transferred to Walnut Hills as a part-time teacher, “and then requested that his position be increased to full-time by assigning him to monitor two study hall periods.” (Decision at 3.) Appellant’s “request to be increased to a full-time status was denied, and another part-time teacher was ultimately assigned to monitor the two study hall periods and an additional teacher was also hired to monitor other available study hall periods.” (Decision at 3.) {¶ 6} Beginning on September 19, 2018, Joseph Stewart (hereafter “Stewart”), the assistant principal of Walnut Hills, who “was a part of the interview committee and named No. 24AP-283 3

in [appellant’s] initial grievance, exchanged a series of emails with [appellant] instructing him to meet with the other seventh grade teachers on his social studies team.” (Decision at 3.) On September 26, 2018, Stewart stopped by appellant’s classroom “to observe [appellant] teaching, and the following day Walnut Hills High School Principal, John Chambers, also stopped by [appellant’s] classroom to observe [appellant] teaching.” (Decision at 3.) {¶ 7} On October 22, 2018, appellant (without union participation) filed an unfair labor practice (“ULP”) charge against the district, alleging it “retaliated against him in response to his filing a grievance by (1) thwarting his efforts to obtain a full-time course load; (2) making requests that he meet with other teachers when similar requests were not made to other teachers; and (3) by coming into his classroom to observe him teaching.” (Decision at 3-4.) {¶ 8} On February 25, 2019, “after receiving responses and evidence from both parties,” a SERB investigator “issued an Investigator’s Memorandum recommending that [appellant’s] charge be dismissed for lack of probable cause to believe that an unfair labor practice had been committed by the District.” (Decision at 4.) On March 14, 2019, SERB dismissed appellant’s ULP charge “for lack of probable cause to believe the statute had been violated.” (Decision at 4.) Finding the district complied with the arbitration decision, SERB further determined appellant “failed to demonstrate that adverse action was taken against him” by the district, and that he “failed to show a nexus between the filing of the grievance and him not being selected for the full-time position.” (Decision at 4.) Appellant filed a motion for reconsideration, which SERB denied. {¶ 9} On August 12, 2019, appellant “was returned to full-time status and given a full-time position at Walnut Hills High School for the 2019-2020 school year.” (Decision at 4.) On August 14, 2019, appellant filed a complaint in the Hamilton County Court of Common Pleas, “seeking a writ of mandamus directing SERB to investigate the ULP charge and to conduct a hearing on the merits of the ULP charge as allegedly required by R.C. 4117.02.” (Decision at 4.) {¶ 10} On October 7, 2021, the trial court denied appellant’s request for a writ of mandamus, and appellant appealed that decision. On August 19, 2022, the First District Court of Appeals, in State ex rel. Thelen v. State Emp. Relations Bd., 2022-Ohio-2883 (1st No. 24AP-283 4

Dist.), reversed the decision of the trial court, holding the court erred in denying the requested writ on the basis that the ULP charge had been determined by the arbitrator (i.e., given that the arbitration proceeding was limited to determining the merits of the grievance and did not concern the ULP charge). The appellate court remanded the matter to the trial court “with instructions to issue a writ of mandamus compelling SERB to investigate the merits of Thelen’s retaliation claim.” Id. at ¶ 29. {¶ 11} On December 1, 2022, in accordance with the ruling of the First District, SERB “vacated its previous directive and reopened its investigation.” (Decision at 5.) On February 3, 2023, “after receiving additional evidence and responses from both parties, a different SERB Investigator issued another Investigator’s Memorandum, which again recommended that [appellant’s] ULP charge be dismissed for lack of probable cause to believe that an unfair labor practice had been committed by the District.” (Decision at 5.) {¶ 12} On February 17, 2023, SERB “dismissed the ULP charge with prejudice for lack of probable cause to believe that the District violated R.C.

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2025 Ohio 2239, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-thelen-v-state-emp-relations-bd-ohioctapp-2025.