McKenzie v. Meijer, Inc., 89 N.E.3d 18

McKenzie, a Meijer employee, sustained a 2001 work-related injury allowed for a lacerated right hand, reflex sympathetic dystrophy of the right upper extremity, and depressive disorder.
In 2015 she sought a scheduled loss award for complete loss of use of her right upper arm; Meijer conducted surveillance showing her using both arms, and she withdrew the scheduled-loss request.
McKenzie requested authorization for 16 chiropractic treatments; Meijer denied the request after an independent medical exam and surveillance evidence.
The Industrial Commission hearing officer and a Staff Hearing Officer affirmed denial, finding treatments not medically reasonable, appropriate, or necessary given her allowed conditions.
McKenzie appealed to the Clermont County Court of Common Pleas; Meijer moved to dismiss for lack of subject-matter jurisdiction under Civ.R. 12(B)(1). The common pleas court granted the motion, and McKenzie appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the common pleas court had jurisdiction to review the Industrial Commission's denial of chiropractic treatment	McKenzie: denial effectively terminated her continued participation in workers' compensation, so R.C. 4123.512(A) permits appeal	Meijer: denial concerned extent of disability under an existing claim, not termination of participation, so no right-to-participate appeal	Court: dismissal affirmed — denial was an extent-of-disability decision not appealable to common pleas court

State ex rel. Liposchak v. Indus. Comm'n, 90 Ohio St.3d 276 (2000) (distinguishes right-to-participate issues from extent-of-disability matters)
Thomas v. Conrad, 81 Ohio St.3d 475 (1998) (extent-of-disability determinations are not reviewable by common pleas; mandamus is the proper remedy)
State ex rel. Evans v. Indus. Com. of Ohio, 64 Ohio St.3d 236 (1992) (denial of additional benefits under an existing claim does not determine right to participate and is not appealable under R.C. 4123.519)