Ryncarz v. Belmont Cnty. Court of Common Pleas Juvenile Court Div., 2017 Ohio 4423

Ryncarz was an at-will deputy clerk in the Belmont County Juvenile Division from 1985 and became Chief Deputy Clerk in 2010; she was 47 when terminated in March 2014 and near retirement eligibility.
From 2009 onward formal semi-annual evaluations praised her work but repeatedly noted communication and attitude problems with coworkers.
In November 2013 Judge Costine issued a written warning citing ongoing passive-aggressive behavior, poor communication, and supervisory deficiencies and warned such conduct could result in termination.
Judge Costine testified Ryncarz’s attitude did not improve and terminated her on March 12, 2014; the duties were covered temporarily and Rebecca Gibson was promoted to Chief Deputy several months later.
Ryncarz sued for age discrimination under R.C. 4112.14, alleging her termination was age-based and that her replacement(s) were substantially younger; the Juvenile Division moved for summary judgment.
Trial court granted summary judgment for the Juvenile Division; the appellate court affirmed, concluding Ryncarz failed to prove she was replaced by a substantially younger person and failed to show pretext.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ryncarz established prima facie age-discrimination by showing she was replaced by a substantially younger person	Ryncarz argued her termination allowed hiring/retention of substantially younger employees and relied on Judge Costine’s awareness of her impending retirement	Juvenile Division showed Gibson (promoted into Chief Deputy) was 63 and other hires were not younger replacements; temporary coverage and redistribution do not constitute replacement	Court held Ryncarz failed to show she was replaced by a substantially younger person and thus failed prima facie proof
Whether the employer’s stated reason (poor attitude/communication) was pretext for age discrimination	Ryncarz pointed to generally positive evaluations and the judge’s knowledge of her near-retirement as evidence of pretext	Juvenile Division produced progressive discipline, written reprimand, deposition/affidavit evidence of ongoing interpersonal problems and contemporaneous documentation	Court held even if prima facie established, Ryncarz did not produce evidence that the stated non‑discriminatory reason was pretextual

Grafton v. Ohio Edison Co., 77 Ohio St.3d 102 (de novo review standard on summary judgment)
Temple v. Wean United, Inc., 50 Ohio St.2d 317 (summary judgment standard; view facts in favor of nonmoving party)
Dresher v. Burt, 75 Ohio St.3d 280 (moving party burden; reciprocal burden of nonmoving party)
Coryell v. Bank One Trust Co., N.A., 101 Ohio St.3d 175 (definition of "substantially younger" is case-specific)
Kohmescher v. Kroger Co., 61 Ohio St.3d 501 (employer may proffer nondiscriminatory reason after prima facie case)
Potts v. Catholic Diocese of Youngstown, 159 Ohio App.3d 315 (elements of prima facie age discrimination)
Manofsky v. Goodyear Tire & Rubber Co., 69 Ohio App.3d 663 (plaintiff must show employer's reason is pretext)
Cassel v. Schuster Electronics, Inc., 159 Ohio App.3d 224 (rules on when reassignment among existing employees is not a replacement)
Hoyt, Inc. v. Gordon & Assoc., Inc., 104 Ohio App.3d 598 (materiality depends on substantive law)
Brewer v. Cleveland Bd. of Edn., 122 Ohio App.3d 378 (nonmoving party must produce some evidence to create genuine issue)