State Ex Rel. Cydrus v. Ohio Public Employees Retirement System, 127 Ohio St. 3d 257

Patricia D. Cydrus, a former executive secretary for the Ohio Department of Youth Services and member of the Ohio Public Employees Retirement System, had disability-retirement benefits terminated after examinations showed no permanent disability.
The retirement board ordered further examinations by psychiatrists and neurologists in 2008; a medical advisor later recommended termination based on insufficient objective evidence of permanent disability.
The board terminated benefits on November 13, 2008 and notified Cydrus of possible appeal with evidence deadlines.
Cydrus submitted additional medical evidence, including a report from her treating physician, after the deadlines, which the board considered in its final decision.
Cydrus filed a mandamus action in the Court of Appeals seeking vacatur or a more detailed explanation of the termination; the court denied relief and the case proceeded to the Ohio Supreme Court for review.
The Supreme Court affirmed, holding the board did not abuse its discretion and had no statutory or constitutional duty to provide a more detailed explanation of its termination decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the board’s lack of explicit reasons violates separation of powers	Cydrus argues the board must explain its decision to comply with separation of powers	Board asserts no statutory duty to explain under governing rules	No separation-of-powers violation; no duty to explain required by statute or rule
Whether due process requires a more detailed termination decision	Cydrus contends due process demands more explicit reasoning	Board relied on objective medical evidence and advised opportunity to submit evidence	Due process does not require a more detailed explanation
Whether mandamus can compel a more detailed decision or vacatur	Relies on mandamus to overturn termination or force explanation	No abuse of discretion shown; board’s decision supported by evidence	Writ denied; no abuse of discretion established
Whether the board properly relied on medical evidence to terminate	Steiman’s report and others show permanent disability	Steiman’s findings are valid and sufficient to terminate; other opinions do not override it	Board’s reliance on Steiman’s report supported termination as supported by substantial evidence
Whether new medical evidence submitted after deadlines could alter the decision	Additional evidence from treating physician should have been considered	New evidence submitted after deadlines was not required to be considered under 145-2-23(B)(3)	Board did not abuse discretion in discounting late evidence; decision upheld

Pipoly v. Pub. Emps. Retirement Sys., 95 Ohio St.3d 327 (2002-Ohio-2219) (mandamus when no statutory right of appeal; board’s discretion review)
VanCleave v. School Emps. Retirement Sys., 120 Ohio St.3d 261 (2008-Ohio-5377) (due process and sufficient process in disability determinations)
Van Dyke v. Pub. Emps. Retirement Bd., 99 Ohio St.3d 430 (2003-Ohio-4123) (court discusses waiver and review of constitutional claims)
Shafer v. Ohio Turnpike Comm., 159 Ohio St. 581 (1953) (claim of administrative due process and presumed regularity)
Haylett v. Ohio Bur. of Workers’ Comp., 87 Ohio St.3d 325 (1999) (due process and reliance on medical evidence in disability determinations)