Jackson v. Ohio Dept. of Rehab. & Corr., 2020 Ohio 1518

Plaintiff Sonya R. Jackson, an ODRC inmate, was transferred from Northeast Reintegration Center (NERC) to the Ohio Reformatory for Women (ORW) on December 28, 2016.
Jackson sued ODRC in the Court of Claims (filed April 27, 2018) seeking damages and an order to be returned to NERC, alleging filthy conditions, emotional harm, loss of visitation, and characterizing the transfer as punishment/retaliation.
ODRC moved to dismiss under Civ.R. 12(B)(1) for lack of subject-matter jurisdiction, arguing Jackson’s claims were constitutional/§1983 in nature.
The Court of Claims dismissed the constitutional claims but allowed that the complaint might be read as challenging an executive transfer decision (a nonconstitutional claim), so it did not dismiss the entire complaint.
ODRC then moved for judgment on the pleadings under Civ.R. 12(C), arguing discretionary immunity and failure to state a nonconstitutional claim; the Court of Claims granted judgment on the pleadings and dismissed the remainder.
The Tenth District Court of Appeals affirmed, concluding the complaint alleged only constitutional/§1983 claims and did not state an independent nonconstitutional cause of action cognizable in the Court of Claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Court of Claims has subject-matter jurisdiction over Jackson's claims	Jackson argued her transfer and resulting conditions gave rise to damages and relief in the Court of Claims	ODRC argued the claims are constitutional/§1983 in nature, so the Court of Claims lacks jurisdiction	The court held the claims are constitutional (conditions/retaliation) and the Court of Claims lacks jurisdiction to hear them
Whether alleging a violation of ODRC policy creates a standalone cause of action	Jackson pointed to ODRC policy violations to support her claim about an improper transfer	ODRC argued internal policy violations alone do not create a cause of action absent a pleaded tort (e.g., negligence)	The court held that alleging violation of internal rules does not, by itself, create a cognizable claim in the Court of Claims
Whether dismissal on Civ.R. 12(C) was proper based on discretionary immunity / failure to state a nonconstitutional claim	Jackson contended she had relief available and the court erred in dismissing	ODRC argued discretionary immunity shields transfer/placement decisions and no nonconstitutional claim was alleged	The court affirmed dismissal, concluding no viable nonconstitutional claim existed; discretionary immunity issues were unnecessary to the disposition

State ex rel. Carter v. Schotten, 70 Ohio St.3d 89 (1994) (inmate complaints about conditions of confinement are treated as §1983/constitutional claims)
State ex rel. Columbia Gas of Ohio, Inc. v. Henson, 102 Ohio St.3d 349 (2004) (a complaint’s substance, not the label, controls jurisdiction; legal labels alone insufficient)
Franks v. Ohio Dept. of Rehab. & Corr., 195 Ohio App.3d 114 (2011) (standards for reviewing Civ.R. 12(C) motions; de novo review)