State ex rel. Belle Tire Distribs., Inc. v. Indus. Comm. (Slip Opinion), 116 N.E.3d 102

Herbert Melroy died on November 19, 2014; his spouse, Judy Melroy, filed for workers' compensation death benefits and the Bureau denied the claim.
The Industrial Commission initially vacated the denial, then a staff hearing officer reversed and denied the claim; the commission refused further review.
Melroy sought reconsideration; the commission found a clear mistake of fact and, on reconsideration, allowed the death-benefit claim.
Employer Belle Tire filed a mandamus petition in the Tenth District, asserting the commission abused its discretion in invoking continuing jurisdiction under R.C. 4123.52.
The court of appeals dismissed the mandamus petition, holding Belle Tire had an adequate remedy by appeal under R.C. 4123.512; the Supreme Court reversed and remanded.
The Supreme Court majority held the commission’s exercise of continuing jurisdiction is reviewable in mandamus (per Saunders), while dissent argued the claim was appealable under R.C. 4123.512 (per Alhamarshah/Carroll).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Belle Tire may seek mandamus to challenge the commission's decision to exercise continuing jurisdiction (vs. being limited to appeal under R.C. 4123.512)	Belle Tire: R.C. 4123.512 does not provide an adequate remedy to challenge the commission's decision to reopen based on a claimed clear mistake of fact; mandamus is appropriate to review abuse of discretion	Melroy & Commission: An R.C. 4123.512 appeal is a plain, adequate remedy because the commission's reopening was essential to the ultimate right-to-participate determination	Majority: Mandamus is available to review the commission's exercise of continuing jurisdiction ( Saunders controls ); court of appeals reversed and case remanded for merits. Dissent: Appeal under R.C. 4123.512 is adequate (would affirm dismissal).

State ex rel. Saunders v. Metal Container Corp., 52 Ohio St.3d 85 (Ohio 1990) (mandamus proper to challenge commission's exercise of continuing jurisdiction based on mistake of fact)
State ex rel. Alhamarshah v. Indus. Comm., 142 Ohio St.3d 524 (Ohio 2015) (mandamus denied where R.C. 4123.512 appeal provided adequate remedy because jurisdictional ruling was essential to right-to-participate determination)
State ex rel. Carroll v. Galion Assisted Living, Ltd., 149 Ohio St.3d 326 (Ohio 2016) (followed Alhamarshah; appeal under R.C. 4123.512 was adequate remedy after commission exercised continuing jurisdiction)
State ex rel. Liposchak v. Indus. Comm., 90 Ohio St.3d 276 (Ohio 2000) (distinguishes right-to-participate orders subject to R.C. 4123.512 appeals)
Ferguson v. State, 151 Ohio St.3d 265 (Ohio 2017) (R.C. 4123.512 appeals are de novo in common pleas courts on right-to-participate issues)