Dikong v. Ohio Supports, Inc., 985 N.E.2d 949

Dikong filed for unemployment in 2010; initial approval then denial by the Ohio Department of Job and Family Services (ODJFS) after an admin hearing.
Dikong appealed the denial; the Commission affirmed, finding no good cause for missing a Commission hearing.
Dikong appealed to the Hamilton County court of common pleas, naming Ohio Supports, Inc. and the Commission but not the ODJFS director.
The Commission moved to dismiss for lack of subject-matter jurisdiction under R.C. 4141.282(D); Dikong later sought to amend to add the director.
The trial court adopted the magistrate’s dismissal for lack of jurisdiction; Dikong appeals pro se.
The court ultimately holds that the director must be named in the notice of appeal as a condition of jurisdiction, and the amendment after the 30-day window cannot cure the defect; the dismissal was proper.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the director’s name is a jurisdictional requirement under R.C. 4141.282(D).	Dikong argues C requires only timely filing, not naming the director.	Defendants contend D makes the director an indispensable party, giving the court no jurisdiction without naming him.	Yes, naming the director is a jurisdictional prerequisite; failure to name it deprives the court of jurisdiction.

Morrison v. Steiner, 32 Ohio St.2d 86 (1972) (defines subject-matter jurisdiction standard and de novo review on appeal of jurisdictional issues)
Gary Phillips & Assocs. v. Ameritech Corp., 144 Ohio App.3d 149 (2001) (jurisdictional review and statutory interpretation principles)
In re Claim of King, 62 Ohio St.2d 87 (1980) (statutory requirements for appeals; mandatory requirements affect jurisdiction)
Rosen v. Celebreeze, 117 Ohio St.3d 241 (2008) (clarifies strict compliance with special statutory appeal provisions)
Zier v. Bureau of Unemp. Comp., 151 Ohio St. 123 (1949) (establishes conditional, mandatory requirements for unemployment appeals)