State ex rel. Cline v. Abke Trucking, Inc., 2013 Ohio 5159

Cline was injured August 27, 2008 as a truck driver for Abke Trucking; claim allowed for left hip contusion and later bursitis.
Cline was placed on medical restrictions and worked offsite for Abke with documentation responsibilities.
On March 25, 2009, Cline was released to return to work with no restrictions; two days later Abke terminated him for insulin use and alleged time-card falsification.
Cline began temporary-total-disability benefits July 1, 2009; district hearing officer affirmed.
In December 2009, a staff hearing officer denied TTD, finding Cline’s termination for violating work rules constituted voluntary abandonment.
The Tenth District Court of Appeals held the commission abused its discretion and could not bar TTD based on insulin-dependent diabetes and alleged falsification, prompting the Supreme Court’s limited mandamus review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the December 2009 order complies with Noll	Cline argues the order lacks stated evidence and rationale.	Abke argues the order appropriately applied discretionary rules.	Order insufficient under Noll; must be detailed.
Whether termination for misconduct equals voluntary abandonment if rules are violated	Cline contends misconduct related to time cards does not defeat disability claim.	Industrial Commission reasoned termination constitutes abandonment when rules are clearly defined and known.	We require explicit reasoning and evidence tying abandonment to the misconduct.

State ex rel. Noll v. Indus. Comm., 57 Ohio St.3d 203 (1991) (adminic materiality of detailed reasoning for denial orders)
State ex rel. Mitchell v. Robbins & Myers, Inc., 6 Ohio St.3d 481 (1983) (minimum standards for commission orders)
State ex rel. Kinnear Div., Harsco Corp. v. Indus. Comm., 77 Ohio St.3d 258 (1997) (need for explicit rationale and evidence citation)
State ex rel. Louisiana-Pacific Corp. v. Indus. Comm., 72 Ohio St.3d 401 (1995) (voluntary abandonment when injury not the cause of wage loss)
State ex rel. Burley v. Coil Packing, Inc., 31 Ohio St.3d 18 (1987) (commission discretion in determining abandonment )