Madyda v. Ohio Dept. of Pub. Safety
2024 Ohio 3201
Ohio Ct. App.2024Background
- The Ohio Department of Public Safety (DPS) is responsible for overseeing driver's licenses and ID cards through deputy registrars, who act as independent contractors on behalf of the state.
- Before July 2, 2018, deputy registrars printed, laminated, and issued credentials onsite, charging up to $1.50 for lamination, as authorized by statute.
- Starting July 2, 2018, DPS transferred credential production (including lamination) to Veridos, a private company, but deputy registrars continued collecting the $1.50 fee though they no longer performed lamination.
- Between July 2, 2018 and July 2, 2019, deputy registrars collected over $5 million in lamination fees without providing the lamination service themselves or remitting any portion to DPS or BMV.
- Plaintiffs initiated a class action, alleging that collecting the lamination fee under these circumstances was unauthorized and constituted unjust enrichment to DPS.
- The trial court ruled for DPS, finding statutory authority to collect the fee remained during the transition period, and dismissed the unjust enrichment claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether deputy registrars could collect a $1.50 lamination fee when they no longer performed lamination | The deputy registrars exceeded authority by charging for an unprovided service, as statutes only permitted fees for actual services rendered. | Statutory language allowed the fee for laminating credentials, regardless of who performed the lamination, as long as the credential was laminated. | Court held the fee was properly collected under the statute, which was clear and unambiguous. |
| Whether DPS was unjustly enriched by receipt/retention of lamination fees during this period | DPS retained a benefit by keeping fees without providing or bearing cost of the service; thus, enrichment was unjust. | DPS used the collected fees to reimburse itself for costs paid to private vendor; recipients got laminated credentials as required. | No unjust enrichment: plaintiffs received benefit paid for (laminated credentials) and DPS acted within statutory authorization. |
Key Cases Cited
- State ex rel. Plain Dealer Publishing Co. v. Cleveland, 106 Ohio St.3d 70 (Ohio 2005) (statutory interpretation focuses on unambiguous statutory text)
- Hambleton v. R.G. Barry Corp., 12 Ohio St.3d 179 (Ohio 1984) (sets elements for unjust enrichment in Ohio)
- Hughes v. Oberholtzer, 162 Ohio St. 330 (Ohio 1954) (purpose of unjust enrichment is to compensate for benefit conferred, not plaintiff's loss)