B.H. v. Dept. of Admin. Servs., 103 N.E.3d 169

Background

B.H., a state employee, covered his son R.H. on the state health plan; R.H. received residential mental-health treatment in Virginia from July 2012 to July 2013.
UnitedHealth (the plan administrator) allegedly denied coverage via letters in July and August 2012; appellants paid $134,600 and sued for declaratory relief and damages (they sought ~60% of the cost, $80,600), plus interest and fees.
Appellants sued both United and the Ohio Department of Administrative Services (DAS) in Franklin County Common Pleas, alleging denial of coverage, breach of fiduciary duty, and statutory/fiduciary entitlement to benefits.
United and DAS moved for judgment on the pleadings, arguing the Common Pleas Court lacked subject-matter jurisdiction because claims for money against the State are within the exclusive jurisdiction of the Ohio Court of Claims.
The trial court granted both motions and dismissed without prejudice; the appellate court dismissed the appeal as to United for lack of a final appealable order but treated the DAS dismissal as appealable and reviewed whether relief sought was legal (money damages) or equitable (specific restitution).
The Tenth District held the compensation sought from DAS was money damages sounding in law (not an equitable specific remedy), so the Court of Claims has exclusive jurisdiction; it affirmed the judgment for DAS and dismissed the appeal as to United for lack of finality.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Common Pleas had subject-matter jurisdiction over claims against United (plan administrator).	United's breaches are independent fiduciary claims that may proceed in Common Pleas.	Dismissal: claims against the State/plan administrator implicate Court of Claims jurisdiction.	Appeal as to United dismissed for lack of final, appealable order (dismissal without prejudice).
Whether Common Pleas had subject-matter jurisdiction over claims against DAS (State).	The relief sought is equitable restitution (specific remedy) from DAS, so Common Pleas has jurisdiction.	The relief sought is money damages sounding in law; exclusive Court of Claims jurisdiction applies.	Held for DAS: claims against DAS seek money damages (legal), so Court of Claims has exclusive jurisdiction; Common Pleas lacked jurisdiction and judgment for DAS affirmed.
Whether appellants' characterization of relief controls forum (money vs equitable).	Characterization as restitution/declaratory relief should place case in equity forum.	Substance of relief controls; if essence is compensation, it's legal damages.	Court looks to nature of relief, not labels; here relief is compensatory, therefore legal.
Whether dismissal without prejudice is a final, appealable order when refiling would be futile or statute-barred.	Immediate appeal permitted to review jurisdictional rulings.	Dismissal without prejudice normally is not final; may be refiled.	Dismissal for lack of jurisdiction may be appealable when refiling in same forum is futile or statute-of-limitations bars refiling; applied to DAS dismissal as appealable.

Key Cases Cited

National City Commercial Capital Corp. v. AAAA at Your Serv., 114 Ohio St.3d 82 (2007) (dismissal without prejudice generally not final and appealable)
Vaccariello v. Smith & Nephew Richards, Inc., 94 Ohio St.3d 380 (2002) (savings statute requires original timely filing to preserve refiling period)
Ohio Academy of Nursing Homes v. Ohio Dept. of Job & Family Servs., 114 Ohio St.3d 14 (2007) (distinguishing compensatory money damages from equitable specific remedies)
Great-West Life & Annuity Ins. Co. v. Knudson, 534 U.S. 204 (2002) (characterization of relief as compensatory money damages vs. specific equitable relief)
Santos v. Ohio Bur. of Workers' Comp., 101 Ohio St.3d 74 (2004) (suits seeking payment of money typically constitute money damages)
Zelenak v. Indus. Comm., 148 Ohio App.3d 589 (2002) (look to nature of relief rather than pleading labels to determine forum jurisdiction)