State ex rel. Toledo Hosp. v. Olender

CourtOhio Court of Appeals
DecidedMay 5, 2026
DocketL-25-00294
StatusPublished

This text of State ex rel. Toledo Hosp. v. Olender (State ex rel. Toledo Hosp. v. Olender) 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. Toledo Hosp. v. Olender, (Ohio Ct. App. 2026).

Opinion

[Cite as State ex rel. Toledo Hosp. v. Olender, 2026-Ohio-1631.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT LUCAS COUNTY

State ex rel. The Toledo Hospital Court of Appeals No.L-25-00294

Relator

v.

The Honorable Lori Olender DECISION AND JUDGMENT

Respondent Decided: May 5, 2026

*****

SULEK, J.

{¶ 1} This matter is before the court on the motions of relator Hon. Lori Olender

and intervenor The Estate of Yvonne Diller (“Estate”) to dismiss respondent The Toledo

Hospital’s complaint for a writ of prohibition. For the reasons that follow, Judge

Olender’s motion to dismiss is granted, the Estate’s motion to dismiss is denied as moot,

and the complaint for a writ of prohibition is dismissed. I. Factual Background and Procedural History

{¶ 2} Toledo Hospital is a defendant in a civil case before Judge Olender, which

was brought by the Estate for allegedly negligent medical treatment that caused Diller’s

death.

{¶ 3} On May 11, 2023, Diller presented to Toledo Hospital with complaints of

toe pain. She was treated by Dr. Jacob Goliver, who consulted with Sohaib Lateef, M.D.,

an employee of the University of Toledo Medical Center. Diller later suffered a severe

stroke, which resulted in her death on July 11, 2023.

{¶ 4} The Estate filed its wrongful death action in case No. CI-2024-01572 against

Toledo Hospital. It alleged that Diller’s death was proximately caused by Dr. Lateef’s

medical negligence and that Toledo Hospital was vicariously liable for Dr. Lateef’s

actions on the basis of agency-by-estoppel.

{¶ 5} On July 30, 2024, the trial court granted a stay of the wrongful death action

pending a determination by the court of claims whether Lateef was entitled to immunity

as a state employee under R.C. 9.86. On October 18, 2024, the court of claims

determined that he was immune. It held that “Ohio courts of common pleas do not have

jurisdiction over civil actions against Dr. Lateef arising out of his care and treatment of

Yvonne Diller on May 11, 2023, at ProMedica Health System in Toledo, Ohio.” Diller v.

University of Toledo College of Medicine and Life Sciences, Ct. of Cl. No. 2024-

00355JD.

2. {¶ 6} Following the determination of Dr. Lateef’s immunity, the Estate voluntarily

dismissed its complaint. On March 10, 2025, it refiled its complaint in case No. CI-2025-

00836. The case was assigned to Judge Olender.

{¶ 7} Toledo Hospital moved to dismiss the complaint, arguing that the trial court

lacked subject-matter jurisdiction. It alleged that the Estate could not pursue a vicarious

liability claim against it for the negligence of Dr. Lateef because he was solely employed

by the State and any claims must, therefore, be made through the court of claims. The

trial court denied Toledo Hospital’s motion to dismiss on October 24, 2025.

{¶ 8} On December 5, 2025, Toledo Hospital filed in this court the current

complaint for a writ of prohibition. The complaint seeks an order of this court

prohibiting Judge Olender from exercising judicial power over the underlying claim in

case No. CI-2025-00836. Subsequently, the Estate moved to intervene. On February 25,

2026, this court granted the Estate’s motion to intervene and issued an alternative writ

ordering Judge Olender either to do the act requested by Toledo Hospital or show cause

why she is not required to do so by filing an answer or a motion to dismiss.

{¶ 9} Judge Olender filed her motion to dismiss on March 11, 2026. In it, she

argues, inter alia, that R.C. 2305.01 grants the court of common pleas general subject-

matter jurisdiction over civil actions. She notes that R.C. 2743.02 does provide the court

of claims with exclusive subject-matter jurisdiction in certain circumstances, but “only in

civil actions brought against employees and officers of the State of Ohio--not to a private

entity such as [Toledo Hospital].” She maintains, therefore, that Toledo Hospital cannot

3. demonstrate a “patent and unambiguous” lack of subject-matter jurisdiction. The Estate,

as intervenor, makes similar arguments in its own motion to dismiss.

{¶ 10} In response, Toledo Hospital argues that under R.C. 2743.02 the court of

claims “has exclusive jurisdiction over all claims arising out of Dr. Lateef’s alleged

negligence.” It asserts that because the Estate’s claim against it arises solely out of the

alleged negligence of Dr. Lateef, the claim “is purely derivative and cannot be

maintained independently of a claim against Dr. Lateef, a state-employed physician that

the Court of Claims has held is immune from suit.” It cites Comer v. Risko, 2005-Ohio-

4559, Fisher v. Van Loveren, 2008-Ohio-4115 (1st Dist.), and Schoewe v. Kosinski,

Lucas C.P. No. CI 2010-06207, 2012 WL 4843144 (Feb. 8, 2012), as examples where

courts have held that private hospitals could not be held liable for the alleged negligence

of state-employed physicians under the theory of agency-by-estoppel.

{¶ 11} Briefing having been completed by the parties, the matter is now

decisional.

II. Analysis

{¶ 12} “A Civ.R. 12(B)(6) motion to dismiss is procedural and tests the

sufficiency of the complaint.” Fisher v. Smith & Lehrer Co., L.P.A., 2024-Ohio-1177, ¶

11 (6th Dist.), quoting NZR Retail of Toledo, Inc. v. Beck Suppliers, Inc., 2016-Ohio-

3205, ¶ 12 (6th Dist.). “To dismiss a complaint under Civ.R. 12(B)(6), ‘it must appear

beyond doubt that the plaintiff can prove no set of facts in support of the claim that would

entitle the plaintiff to the relief sought.’” Id., quoting Ohio Bur. of Workers’ Comp. v.

McKinley, 2011-Ohio-4432, ¶ 12. “In considering the motion, the court must accept as

4. true all factual allegations in the complaint and construe any reasonable inferences in

favor of the non-moving party.” Id., citing Alford v. Collins-McGregor Operating Co.,

2018-Ohio-8, ¶ 10.

{¶ 13} “A writ of prohibition is an extraordinary writ that a court does not grant

routinely or easily.” State ex rel. Allenbaugh v. Sezon, 2023-Ohio-1754, ¶ 11. To be

entitled to a writ of prohibition, Toledo Hospital must demonstrate that: (1) Judge

Olender is about to exercise or has exercised judicial power; (2) the exercise of that

power is unauthorized by law; and (3) denying the writ would result in injury for which

no other adequate remedy exists in the ordinary court of the law. Id.

{¶ 14} Here, Toledo Hospital cannot satisfy all the elements for a writ of

prohibition because it has an adequate remedy at law by way of an appeal following final

judgment in the common pleas court. The sole issue then is whether the no-adequate-

remedy requirement is dispensed with because the common pleas court “patently and

unambiguously lacks subject-matter jurisdiction over a cause of action.” Schlegel v.

Sweeney, 2022-Ohio-3841, ¶ 6.

{¶ 15} “‘[W]hen a court has the constitutional or statutory power to adjudicate a

particular class or type of case, that court has subject-matter jurisdiction.’” Id. at ¶ 12,

quoting Ostanek v. Ostanek, 2021-Ohio-2319, ¶ 36. “Common pleas courts ‘have such

original jurisdiction over all justiciable matters… as may be provided by law.” Id.,

quoting Ohio Constitution, Article IV, Section 4(B). “Provided by law” is understood “to

mean that the general subject matter jurisdiction of the common pleas court ‘is defined

5. entirely by statute.’” State ex rel. Gray v.

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Related

Ohio Bureau of Workers' Compensation v. McKinley
2011 Ohio 4432 (Ohio Supreme Court, 2011)
Fisher v. Van Loveren, C-070228 (8-15-2008)
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2018 Ohio 8 (Ohio Supreme Court, 2018)
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2021 Ohio 2319 (Ohio Supreme Court, 2021)
State v. Wilson
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Schlegel v. Sweeney
2022 Ohio 3841 (Ohio Supreme Court, 2022)
State ex rel. Gray v. Kimbler
2022 Ohio 3937 (Ohio Supreme Court, 2022)
Clawson v. Hts. Chiropractic Physicians, L.L.C.
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State ex rel. Allenbaugh v. Sezon
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Fisher v. Smith & Lehrer Co., L.P.A.
2024 Ohio 1177 (Ohio Court of Appeals, 2024)

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