Myles v. Twin Valley Behavior Healthcare
2021 Ohio 2119
Ohio Ct. App.2021Background
- Ronald R. Myles filed a complaint in the Court of Claims on May 4, 2020 against Twin Valley Behavior Healthcare alleging medical malpractice and constitutional violations related to a diagnosis of mental incompetence.
- Two other non-state defendants were dismissed sua sponte, leaving Twin Valley as sole defendant.
- Twin Valley moved to dismiss under Civ.R. 12(B)(1) (lack of subject-matter jurisdiction) and 12(B)(6) (failure to state a claim); Myles filed a response and a Civ.R. 56 summary-judgment motion.
- The Court of Claims dismissed Myles' constitutional claims for lack of jurisdiction and dismissed the remainder of the complaint under Civ.R. 12(B)(6) as time-barred; it denied Myles' summary-judgment motion as moot.
- Myles relied on Ohio’s savings statute (R.C. 2305.19(A)) and attached prior docket entries to argue timeliness; the court found those prior filings either too remote or nullities and therefore insufficient to save his claims.
- The Tenth District affirmed, noting the Court of Claims properly dismissed for lack of jurisdiction and under the statute of limitations, and that dismissal rendered the summary-judgment motion moot.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Court of Claims has jurisdiction over alleged constitutional claims | Myles asserted constitutional-rights claims against Twin Valley | Twin Valley argued Court of Claims, as a limited-jurisdiction court, lacks power to hear constitutional claims | Held: Court of Claims lacks subject-matter jurisdiction; constitutional claims dismissed under Civ.R. 12(B)(1) |
| Whether complaint states claim or is time-barred | Myles argued the claims were timely (invoking savings statute) | Twin Valley argued the action accrued in 2016 and suit filed in 2020 exceeded the two-year limit under R.C. 2743.16(A) | Held: Complaint is time-barred; dismissed under Civ.R. 12(B)(6) |
| Whether Ohio’s savings statute (R.C. 2305.19(A)) saved the action | Myles claimed prior dismissals constituted failures "otherwise than on the merits," permitting refiling within one year | Twin Valley argued prior dismissals were either too old or the post-judgment filings were nullities and do not trigger the savings statute | Held: Savings statute did not apply — prior dismissal was outside one-year window and attempted reconsideration was a nullity |
| Whether the Court of Claims erred by denying Myles' summary-judgment motion as moot | Myles contended the summary-judgment motion should not have been denied as moot | Twin Valley noted a dispositive dismissal makes a pending summary-judgment motion moot | Held: Denial as moot proper because dispositive dismissal under Civ.R. 12 rendered the summary motion moot |
Key Cases Cited
- O'Brien v. Univ. Community Tenants Union, Inc., 42 Ohio St.2d 242 (1975) (standard for testing sufficiency of complaint under Civ.R. 12(B)(6))
- Mitchell v. Lawson Milk Co., 40 Ohio St.3d 190 (1988) (court must construe complaint in plaintiff's favor on motion to dismiss)
- Celeste v. Wiseco Piston, 151 Ohio App.3d 554 (2003) (dismissal for failure to state a claim when no set of facts would entitle plaintiff to relief)
- Velotta v. Leo Petronzio Landscaping, Inc., 69 Ohio St.2d 376 (1982) (statute-of-limitations dismissal appropriate when complaint shows action is time-barred on its face)
- Collins v. Sotka, 81 Ohio St.3d 506 (1998) (cause of action accrues and limitations run when wrongful act committed)