Martin v. Ohio Dept. of Rehab. & Corr.
2017 Ohio 1124
| Ohio Ct. App. | 2017Background
- William E. Martin, an inmate at Allen Correctional Institution, sued the Ohio Department of Rehabilitation and Correction (ODRC) after he was assaulted by another inmate using golf clubs; Martin alleged physical injuries to his face, eye, ear, and left maxillary sinus.
- Martin alleged ODRC removed a prison putt-putt golf course (because putters could be used as weapons) and that officials had warned/identified him as a snitch to the attacker, supporting constructive knowledge of risk.
- Martin filed an amended complaint in the Court of Claims asserting state-law negligence/personal-injury claims and a due-process/constitutional claim based on his subsequent transfer.
- ODRC moved to dismiss under Civ.R. 12(B)(1) and (B)(6); the Court of Claims granted dismissal on July 19, 2016.
- On appeal, the Tenth District reviewed whether dismissal was proper given notice pleading rules, whether discovery should have been allowed before dismissal, and whether the Court of Claims had jurisdiction over constitutional/Section 1983 claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether dismissal should be stayed to permit discovery | Martin argued the court should allow him to complete requested discovery before deciding dismissal | ODRC argued dismissal under Civ.R.12(B)(6) is governed solely by the complaint; discovery is not required | Denied — discovery request does not prevent a Civ.R.12(B)(6) dismissal; court may consider only the pleadings unless converted to summary judgment |
| Whether Martin stated a viable state-law personal-injury/negligence claim against ODRC | Martin alleged breach of custodial duty, constructive knowledge of danger (golf clubs as weapons), and that officials provided information that led to the attack | ODRC argued the complaint failed to plead necessary elements (e.g., notice) to support liability | Sustained in part — court found Martin pleaded facts (constructive knowledge and state conduct) sufficient to survive dismissal and remanded for further proceedings |
| Whether the Court of Claims had jurisdiction over constitutional and §1983 claims (due process transfer claim) | Martin contended his transfer violated due process and should be adjudicated in the Court of Claims | ODRC argued the Court of Claims lacks subject-matter jurisdiction over constitutional and §1983 claims | Overruled — Court of Claims lacks jurisdiction over constitutional and §1983 claims; dismissal of that claim was proper |
Key Cases Cited
- York v. Ohio State Highway Patrol, 60 Ohio St.3d 143 (1991) (standard for Civ.R. 12(B) dismissal; notice-pleading and set-of-facts test)
- Mitchell v. Lawson Milk Co., 40 Ohio St.3d 190 (1988) (accept factual allegations as true and draw inferences for nonmoving party on motion to dismiss)
- Lin v. Gatehouse Constr. Co., 84 Ohio App.3d 96 (8th Dist.) (1992) (12(B) dismissal standard)
- Powell v. Vorys, 131 Ohio App.3d 681 (10th Dist.) (1999) (trial court on Civ.R.12(B)(6) may consider only statements and facts in the pleadings)
- McGlone v. Grimshaw, 86 Ohio App.3d 279 (4th Dist.) (1993) (appellate review of trial court's dismissal under Civ.R.12)
- Bleicher v. Univ. of Cincinnati College of Med., 78 Ohio App.3d 302 (10th Dist.) (1992) (Court of Claims lacks jurisdiction over constitutional and §1983 claims)