Coleman v. Columbus State Community College
49 N.E.3d 832
Ohio Ct. App.2015Background
- Coleman worked as an associate registrar at Columbus State Community College (CSCC) from July 1, 2009, until her termination on June 8, 2012; she alleges disability (fibromyalgia and polymyalgia rheumatica), failure to accommodate, retaliation, and harassment.
- She filed federal claims (ADA and FMLA), an Ohio disability claim (R.C. 4112.02), and tort claims; she also filed a related federal suit in June 2014 and later voluntarily dismissed it under Fed. R. Civ. P. 41(a)(2).
- Coleman filed a complaint in the Ohio Court of Claims on August 22, 2014; CSCC moved to dismiss under Civ.R. 12(B)(6) arguing the action was time-barred.
- The trial court dismissed the complaint, holding the Court of Claims two-year statute of limitations (R.C. 2743.16(A)) applied and equitable tolling did not save Coleman’s claims.
- Coleman appealed, arguing (1) federal statutes of limitations (not Ohio’s two-year rule) should govern her federal claims; (2) prospective injunctive relief is exempt from state sovereign immunity thus federal limitations should apply; and (3) equitable tolling should extend the limitations period.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal statutes of limitations govern ADA/FMLA claims brought in the Ohio Court of Claims | Coleman: Supremacy Clause requires federal limitation periods govern federal claims; state law cannot shorten federal causes of action | CSCC: Ohio waived immunity conditionally via Court of Claims Act; R.C. 2743.16(A) sets a two-year limit for suits against the state | Court: R.C. 2743.16(A)’s two-year filing requirement applies; federal law did not abrogate state sovereign immunity here; claims untimely |
| Whether prospective injunctive relief claims fall outside sovereign immunity (so federal limitations apply) | Coleman: Injunctive relief is excluded from sovereign immunity protection; thus federal limitations should govern | CSCC: (Responded below) objection that argument was not raised in trial court | Court: Argument forfeited on appeal; court declined to consider it |
| Whether equitable tolling should excuse late filing | Coleman: Exceptional circumstances (delay in receiving right-to-sue letter, exhaustion requirements) justify tolling | CSCC: No extraordinary circumstance or misconduct by defendant prevented timely filing | Court: Equitable tolling denied; plaintiff filed in federal court within two years, and no fraud or misrepresentation by CSCC justified tolling |
Key Cases Cited
- Alden v. Maine, 527 U.S. 706 (1999) (States retain sovereign immunity from private suit in their own courts absent valid congressional abrogation)
- Felder v. Casey, 487 U.S. 131 (1988) (state procedural requirements may be preempted when Congress validly abrogated state immunity under §5 of the Fourteenth Amendment)
- Quern v. Jordan, 440 U.S. 332 (1979) (discussing congressional enactments under §5 and their relation to state immunity)
- Bd. of Trustees of Univ. of Ala. v. Garrett, 531 U.S. 356 (2001) (Congress did not validly abrogate state sovereign immunity for Title I ADA money damages claims)
- O'Brien v. Univ. Community Tenants Union, Inc., 42 Ohio St.2d 242 (1975) (standard for testing sufficiency of a complaint under Civ.R. 12(B)(6))
- Mitchell v. Lawson Milk Co., 40 Ohio St.3d 190 (1988) (requirement to construe complaint in plaintiff's favor on a 12(B)(6) motion)
- State ex rel. Sawicki v. Court of Common Pleas of Lucas Cty., 121 Ohio St.3d 507 (2009) (Court of Claims Act is the operative statutory waiver of Ohio's sovereign immunity)