Maurer v. Wayne Cty. Bd. of Cty. Commrs., 2015 Ohio 5318

Thomas Maurer, Wayne County sheriff, and his wife Toni were covered by the County’s employee group health plan.
In Resolution No. 2011-453 the County changed the plan effective Jan 1, 2012 to expressly exclude hearing-related procedures and devices, including cochlear implants.
Toni Maurer was diagnosed with Meniere’s disease and sought a cochlear implant after the exclusion took effect; Aetna initially approved then denied coverage and denied the administrative appeal.
The Maurers paid for the surgery and sued in Wayne County Common Pleas seeking a declaratory judgment that the plan covered the implant.
The trial court granted summary judgment to Wayne County and Aetna, holding the plan unambiguously excluded cochlear implants; the Maurers appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the County could change health coverage for an elected official during his term	Maurer: County’s mid-term change effectively reduced an elected official’s compensation, violating Ohio Const. art. II, §20	County/Aetna: Plan language unambiguously excluded cochlear implants; change was valid and enforceable	Reversed and remanded — trial court failed to address Maurers’ constitutional argument and must consider it first
Whether the plan unambiguously excludes cochlear implants	Maurer: Exclusion may implicate constitutional issue; ambiguity contested	County/Aetna: Plan text clearly excludes cochlear implants and related devices	Not resolved on appeal — appellate court did not rule on coverage because lower court did not address constitutional claim

Grafton v. Ohio Edison Co., 77 Ohio St.3d 102 (standard of review for summary judgment)
Murphy v. Reynoldsburg, 65 Ohio St.3d 356 (summary judgment facts viewed in favor of nonmoving party)
Dresher v. Burt, 75 Ohio St.3d 280 (burden-shifting framework for summary judgment motions)
State ex rel. Zimmerman v. Tompkins, 75 Ohio St.3d 447 (reciprocal burden of nonmoving party to show genuine issue)