Pintagro v. Sagamore Hills Twp., 2012 Ohio 2284

Pintagro, employed part-time as the trustees’ administrative assistant since 1989, faced alleged harassment by an intern hired by the new fiscal officer.
Ms. Pintagro reported the intern’s conduct to the trustees, who promised to resolve the issue but did not act promptly.
Due to scheduling conflicts on Mondays, the trustees concluded Pintagro could not maintain separate hours from the intern, offering resignation or termination.
Pintagro resigned after learning she would be terminated or forced out and subsequently sued the Township, trustees, and their lawyer for multiple claims.
The trial court granted summary judgment to the defendants on all claims and denied Pintagro’s motion to amend to add an Open Meetings Law claim.
On appeal, Pintagro challenges the summary judgment on retaliation and the denial of leave to amend; the court affirms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Pintagro engaged in a protected activity.	Pintagro opposed harassment by the intern.	There is no evidence the conduct was discriminatory as to Pintagro's protected class.	No protected activity established; retaliation claim fails.
Whether the alleged retaliation was causally connected to Pintagro’s complaint.	Failure to investigate harassment shows retaliatory motive.	No evidence of discriminatory motivation or protected-opposition basis.	No genuine issue of material fact on causation; dismissal proper.
Whether public policy exception to at-will employment supports retaliation claim.	Public policy bars termination for reporting harassment.	No clear public policy violation shown; conduct may be non-discriminatory.	No public policy basis found to override at-will status.
Whether Pintagro should be allowed to amend to add an Open Meetings Law claim.	New evidence from deposition shows potential OM law violation.	Late amendment would prejudice defendants and delay trial.	Trial court acted within proper discretion in denying amendment.

Greer-Burger v. Temesi, 116 Ohio St.3d 324 (2007-Ohio-6442) (elements of retaliation proof in Ohio)
Painter v. Graley, 70 Ohio St.3d 377 (1994) (employment-at-will exceptions require strong public policy)
Collins v. Rizkana, 73 Ohio St.3d 65 (1995) (public policy restraint on employment actions)
Dohme v. Eurand Am. Inc., 130 Ohio St.3d 168 (2011) (limits on expanding public policy grounds)
Sutton v. Tomco Machining Inc., 129 Ohio St.3d 153 (2011) (retaliation evidence considerations in workplace cases)
Peterson v. Teodosio, 34 Ohio St.2d 161 (1973) (standard for leave to amend pleadings)