Measles v. Industrial Commission
128 Ohio St. 3d 458
| Ohio | 2011Background
- Injured workers signed lump-sum-advancement agreements under R.C. 4123.64(A) in lieu of part of their life-long disability benefits.
- The agreements stated that the lump sum would permanently reduce ongoing weekly benefits for the life of the claim.
- BWC and the Commission disbursed the lump sums and reduced weekly payments accordingly; no retroactive code provision applied to these agreements.
- Plaintiffs sought restitution for funds allegedly wrongfully withheld from ongoing benefits, claiming the reductions equaled the lump-sum value (a claim they framed as equity and class-wide).
- Trial court dismissed for lack of subject-matter jurisdiction; appellate court reversed, finding jurisdiction in common pleas, not Court of Claims.
- This Court held that a claim for money due under a contract must be heard in the Court of Claims, thus reversing the appellate court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the claim sound in equity or law? | Measles argues equity restitution applies | Indus. Comm. argues contract-based money damages belong to Court of Claims | Jurisdiction lies in Court of Claims |
| Does the Court of Claims have exclusive jurisdiction over money due under a lump-sum-advancement contract? | Measles seeks contractual restitution in common pleas | State claims are exclusively in Court of Claims for money due under contract | Yes, Court of Claims has exclusive jurisdiction |
| Are Cristino and Santos controlling in determining jurisdiction for lump-sum restitution claims? | Cristino controls, supporting common pleas jurisdiction | Cristino should align with Santos to support Court of Claims | Cristino controls; restitution under contract belongs to Court of Claims |
Key Cases Cited
- Cristino v. Ohio Bur. of Workers’ Comp., 118 Ohio St.3d 151 (2008-Ohio-2013) (restitution under contract is money due; Court of Claims exclusive for such claims)
- Santos v. Ohio Bur. of Workers’ Comp., 101 Ohio St.3d 74 (2004-Ohio-28) (unjust enrichment by state; common pleas may address return of specific funds)
- Ohio Hosp. Assn. v. Ohio Dept. of Human Servs., 62 Ohio St.3d 97 (1991) (Court of Claims exclusive for money damages, even with equitable relief)
- Great-West Life & Annuity Ins. Co. v. Knudson, 534 U.S. 204 (2002) (restitution concepts; money due under contract analyzed under traditional framework)