State ex rel. Daniels v. State Teachers Retirement Sys.
2017 Ohio 7847
| Ohio Ct. App. | 2017Background
- Isiah Daniels retired from STRS in 2005 and elected a "Joint and Survivor Annuity 15 year guaranteed one-half to beneficiary without reversion option," naming his then-spouse Cecilia Maldonado as beneficiary.
- Daniels obtained a divorce in 2016 and a domestic-relations order stating he "may change the beneficiary designation of his STRS pension pursuant to STRS plans, rules, and regulations."
- Daniels submitted a change-of-beneficiary form (seeking to name his daughter and convert to a single life equivalent) with the domestic-relations order; STRS denied the request based on his original election being "without reversion."
- Daniels filed a petition for a writ of mandamus seeking an order directing STRS to allow the beneficiary change and convert his benefit to a single lifetime equivalent under R.C. 3307.60(A)(3).
- The trial court denied mandamus via Civ.R. 12(B)(6), finding Daniels failed to plead a legal duty on STRS to change his beneficiary/plan because he had not elected the option that permits reversion rights.
- The Ninth District affirmed: Daniels’ original election excluded reversion rights, so STRS had no statutory duty to effect the change; Daniels’ reliance on the domestic-relations order did not overcome that statutory limitation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court committed plain error by treating the claim as based on the domestic-relations order rather than statute | Daniels: claim is statutory under R.C. 3307.60(A)(3), not founded on the divorce order; trial court mischaracterized basis | STRS: (implicit) relief depends on statutory entitlement tied to the retirement option selected | Court declined to reach the plain-error argument because Daniels failed to develop it on appeal; issue not addressed on merits |
| Whether STRS had a legal duty under R.C. 3307.60(A)(3) to allow beneficiary change and conversion to single-life equivalent | Daniels: R.C. 3307.60(A)(3) permits reversion to single lifetime benefit after marital termination and thus STRS must allow the change | STRS: Duty depends on which option the retirant selected at retirement; only option 3 contains reversion rights — Daniels chose a plan without reversion | Held for STRS: Daniels selected a plan expressly "without reversion," so R.C. 3307.60(A)(3) does not apply and STRS had no duty to change beneficiary or plan type |
| Whether the domestic-relations order authorized the change despite Daniels’ original election | Daniels: domestic-relations order permits change "pursuant to STRS plans, rules, and regulations" | STRS: The order is limited by STRS plans/statute; it cannot create rights beyond the statutory options elected at retirement | Court: Domestic-relations order cannot override statutory scheme; it would only be effective for a retirant who had elected option 3, which Daniels did not |
| Whether additional statutory/regulatory authorities raised on appeal (R.C. 5815.33(B)(1), R.C. 3307.562, Ohio Adm.Code 3307:2-5-07(A)) support relief | Daniels: alternative statutes/regulations impose duties allowing change | STRS: These arguments were not raised below and thus are forfeited | Court: Declined to consider those authorities because Daniels failed to raise them in the trial court |
Key Cases Cited
- State ex rel. Hanson v. Guernsey Cty. Bd. of Commrs., 65 Ohio St.3d 545 (1992) (motion to dismiss tests complaint sufficiency)
- State ex rel. Fuqua v. Alexander, 79 Ohio St.3d 206 (1997) (trial court may not rely on allegations outside complaint on Civ.R. 12(B)(6))
- State ex rel. Midwest Pride IV, Inc. v. Pontious, 75 Ohio St.3d 565 (1996) (attachments to complaint may be considered when deciding motion to dismiss)
- Mitchell v. Lawson Milk Co., 40 Ohio St.3d 190 (1988) (on a motion to dismiss, factual allegations presumed true and reasonable inferences made for nonmovant)
- O'Brien v. Univ. Community Tenants Union, Inc., 42 Ohio St.2d 242 (1975) (standard that dismissal warranted when no set of facts would entitle plaintiff to relief)
- York v. Ohio State Hwy. Patrol, 60 Ohio St.3d 143 (1991) (if any set of facts consistent with complaint would allow recovery, dismissal improper)
- State ex rel. Russell v. Thornton, 111 Ohio St.3d 409 (2006) (mandamus may be dismissed under Civ.R. 12(B)(6))
- State ex rel. Talwar v. State Med. Bd. of Ohio, 104 Ohio St.3d 290 (2004) (elements required for mandamus relief)