Sampson v. Cuyahoga Metropolitan Housing Authority
131 Ohio St. 3d 418
| Ohio | 2012Background
- CMHA is a metropolitan housing authority and thus a political subdivision eligible for immunity under R.C. Chapter 2744.
- Sampson, CMHA employee, was arrested during a mandatory CMHA meeting after an internal investigation into gasoline-card misuse.
- CMHA publicly announced the arrests via press releases and a press conference; Sampson was jailed briefly and placed on paid leave.
- Criminal charges against Sampson were dismissed with prejudice; CMHA terminated him and he later grieved through arbitration, which reinstated him with back wages and seniority.
- Sampson filed civil claims including intentional tort and negligence against CMHA; the trial court partially granted immunity-based summary judgment but denied it on other grounds.
- Appellate courts held that 2744.09(B) may apply, allowing a merits-focused review of whether the claims arise out of the employment relationship; this Court granted review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 2744.09(B) applies to employee claims for intentional torts against a political subdivision | Sampson: claims are 'relative to' employment and thus outside immunity. | CMHA: Blankenship-type rationale not imported; intentional torts do not arise out of employment. | Yes; 2744.09(B) may apply if a causal connection to the employment exists. |
| Whether Blankenship v. Cincinnati Milacron creates a rule applicable to 2744.09(B) | Blankenship should apply to remove immunity in workplace intentional torts. | Blankenship is inapplicable to political-subdivision immunity due to different policy foundations. | Not incorporated; 2744.09(B) read plainly governs employment-related matters. |
| Whether there is a genuine issue of material fact that Sampson's claims arise out of the employment relationship | Record shows causal links between employment context and alleged torts. | Arguments in record do not show a connection to employment. | Yes; record could support that claims arise from employment, warranting trial. |
Key Cases Cited
- Blankenship v. Cincinnati Milacron Chems., Inc., 69 Ohio St.2d 608 (1982) (workers’ compensation immunity does not bar private tort action when intentional harm is involved)
- Brady v. Safety-Kleen Corp., 61 Ohio St.3d 624 (1991) (court explains Blankenship line of cases on employer intentional torts)
- Kaminski v. Metal & Wire Prods. Co., 125 Ohio St.3d 250 (2010) (evolution of Blankenship doctrine and its limits)
- Estate of Graves v. Circleville, 124 Ohio St.3d 339 (2010) (policy context of political-subdivision immunity)
- Comer v. Risko, 106 Ohio St.3d 185 (2005) (de novo review standard on summary-judgment rulings)