Thompson v. Ohio Bur. of Workers' Comp.

2026 Ohio 720
CourtOhio Court of Appeals
DecidedMarch 3, 2026
Docket25AP-561
StatusPublished

This text of 2026 Ohio 720 (Thompson v. Ohio Bur. of Workers' Comp.) 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
Thompson v. Ohio Bur. of Workers' Comp., 2026 Ohio 720 (Ohio Ct. App. 2026).

Opinion

[Cite as Thompson v. Ohio Bur. of Workers' Comp., 2026-Ohio-720.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

Chesney Nicole Thompson, :

Relator, :

v. : No. 25AP-561

Ohio Bureau of Workers’ : (REGULAR CALENDAR) Compensation et al., : Respondents. :

D E C I S I O N

Rendered on March 3, 2026

On brief: Chesney Nicole Thompson, pro se.

On brief: Dave Yost, Attorney General, and Natalie J. Tackett, for respondent Ohio Bureau of Workers’ Compensation.

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

IN MANDAMUS ON OBJECTIONS TO THE MAGISTRATE’S DECISION

LELAND, J. {¶ 1} Relator, Chesney Nicole Thompson, has filed a petition for a writ of mandamus against respondents, Ohio Bureau of Workers’ Compensation (“bureau”) and the Industrial Commission of Ohio (“commission”). In her pro se petition, relator requests that this court order the commission and bureau to (1) pay her alleged “overdue compensation, penalties, and housing support totaling $1,403,256.80”; (2) order “restitution of unlawfully retained attorney fees . . . totaling $40,753.00”; “[c]ompel No. 25AP-561 2

reinstatement of . . . medical treatment . . . and reversal of fraudulent denials”; and (4) to award “such further relief as justice, equity, and divine reciprocity require.” (Petition for Writ of Mandamus at 3.) Both the bureau and the commission have filed motions to dismiss. {¶ 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 the petition be dismissed sua sponte for failure to comply with the captioning requirement of R.C. 2731.04. Additionally, and alternatively, the magistrate recommends sua sponte dismissal of relator’s petition on the ground it “fails to meet the standard for stating a claim in mandamus because she fails to allege in her petition the absence of an adequate remedy at law.” (Appended Mag.’s Decision at ¶ 53.) {¶ 3} Relator has filed eight pro se objections to the magistrate’s decision, including the assertion (under Objection No. 1) that the magistrate erred by recommending dismissal “based on a captioning technicality.” Relator raises additional objections titled: “OBJECTION TWO: ADEQUATE REMEDY”; “OBJECTION THREE: DEEMED APPROVAL”; “OBJECTION FOUR: VOID SETTLEMENT”; “OBJECTION FIVE: JUDICIAL ESTOPPEL”; “OBJECTION SIX: UNREBUTTED AFFIDAVITS”; “OBJECTION SEVEN: DUE PROCESS VIOLATIONS”; and “OBJECTION EIGHT: IRREPARABLE HARM.” {¶ 4} Under her first objection, relator challenges the magistrate’s determination that this matter should be dismissed sua sponte for failure to comply with the captioning requirement of R.C. 2731.04. Relator argues that such caption errors “are waivable and not jurisdictional,” and cites in support the Supreme Court of Ohio’s decision in Salemi v. Cleveland Metroparks, 2016-Ohio-1192. {¶ 5} The magistrate addressed the decision in Salemi, recognizing the Supreme Court “has previously allowed a petition for a writ of mandamus to proceed even where the petition failed to comply with the captioning requirement in R.C. 2731.04 because ‘the requirements of that statute are not jurisdictional.’ ” (Appended Mag.’s Decision at ¶ 38, quoting Salemi at ¶ 15.) The magistrate noted, however, the Supreme Court more recently, in a merit decision without opinion, “sua sponte dismissed a mandamus complaint without No. 25AP-561 3

prejudice ‘because the complaint was not filed in the name of the State on the relation of the person applying, in violation of R.C. 2731.04.’ ” (Appended Mag.’s Decision at ¶ 38, quoting State ex rel. Harper v. Perlatti, 2025-Ohio-1313, ¶ 15.) The magistrate also cited a recent decision of this court, Wright v. Application for Relief from Disability, 2025-Ohio- 1425, ¶ 5-6 (10th Dist.), in which we held a trial court did not err in sua sponte dismissing a petitioner’s mandamus complaint for failure to comply with the caption requirement of R.C. 2731.04. {¶ 6} R.C. 2731.04 states in part as follows: “Application for the writ of mandamus must be by petition, in the name of the state on the relation of the person applying, and verified by affidavit.” In Wright, this court observed the “[f]ailure to comply with this requirement is grounds for dismissal of a mandamus complaint.” Id. at ¶ 5, citing Shoop v. State, 2015-Ohio-2068, ¶ 10; Blankenship v. Blackwell, 2004-Ohio-5596, ¶ 34; Ashley v. Kevin O’Brien & Assocs. Co., L.P.A., 2022-Ohio-24, ¶ 10 (10th Dist.). {¶ 7} Other Ohio courts have similarly held that, while the requirements of R.C. 2731.04 are “not jurisdictional, . . . a court may dismiss the complaint for failure to comply with the provisions of R.C. 2731.04.” In re Collado, 2020-Ohio-5337, ¶ 8 (8th Dist.), citing Salemi, 2016-Ohio-1192, at ¶ 15; Shoop at ¶ 10, citing Blankenship at ¶ 34. See also Kenard v. Tucker, 2005-Ohio-6834, ¶ 7 (2d Dist.), citing Maloney v. Court of Common Pleas of Allen Cty., 173 Ohio St. 226 (1962) (“[f]ailure to properly caption an original action petition is grounds for denying the writ and dismissing the petition”); Davis v. Lucas Cty. Prosecutor’s Office, 2002-Ohio-4657, ¶ 3 (6th Dist.) (sua sponte dismissing petition for failure to comply with R.C. 2731.04 where “petition presented to this court is not in the name of the state on the relation of Davis” and “[t]his deficiency alone is an adequate reason to deny the petition”); Snype v. Enlow, 2012-Ohio-1272, ¶ 4 (11th Dist.) (“[a] court may sua sponte dismiss a petition for an extraordinary writ when it is improperly captioned”); Spencer v. State, 2020-Ohio-235, ¶ 5 (5th Dist.) (sua sponte dismissing “improperly captioned” writ of mandamus). {¶ 8} Here, as determined by the magistrate, relator failed to comply with the captioning requirement of R.C. 2731.04 by failing to bring her petition for writ of mandamus “in the name of the state on the relation of the person applying.” Such deficiency, as also determined by the magistrate, is grounds for dismissal of a mandamus No. 25AP-561 4

complaint, and we agree with the magistrate’s recommendation to sua sponte dismiss the petition on that basis. Accordingly, relator’s first objection is not well-taken and is overruled. {¶ 9} Under her second objection, relator challenges the magistrate’s conclusion that relator “fails to allege in her petition the absence of an adequate remedy at law.” (Appended Mag.’s Decision at ¶ 53.) However, based on our disposition of the first objection, finding sua sponte dismissal appropriate based on relator’s failure to comply with the captioning requirement of R.C. 2731.04, we need not address the alternative basis for dismissal included in the magistrate’s decision. Accordingly, relator’s second objection is rendered moot. Similarly, we need not address relator’s remaining objections, all of which address the merits of the mandamus petition, as they are also rendered moot. {¶ 10} Following an independent review of this matter, we find the magistrate properly determined relator’s petition is subject to sua sponte dismissal for failure to comply with R.C. 2731.04. Accordingly, we overrule relator’s first objection, rendering relator’s remaining objections moot. We therefore adopt the magistrate’s findings of fact and conclusions of law as our own, except to the extent we decline to address the alternative basis for dismissal as raised in relator’s second objection. In accordance with the magistrate’s recommendation, we sua sponte dismiss relator’s requested writ of mandamus. Finally, and in accordance with the further recommendation of the magistrate, all pending motions are rendered moot. Objections overruled in part and rendered moot in part; writ of mandamus dismissed.

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Bluebook (online)
2026 Ohio 720, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thompson-v-ohio-bur-of-workers-comp-ohioctapp-2026.