State Ex Rel. Guthrie v. Industrial Commission
133 Ohio St. 3d 244
| Ohio | 2012Background
- Guthrie sustained knee injuries causing 20% permanent partial disability and inability to return to nursing aide work.
- She began receiving temporary total disability in 2004 and has not worked since.
- Guthrie completed a four-year graphic-arts program in a vocational rehab, but never secured employment.
- Rehabilitation was conducted through 2009 and ended with closure remarks noting Guthrie’s reluctance to broaden job search.
- The SHO denied PTD, finding Guthrie medically and vocationally capable of sedentary sustained remunerative employment.
- Courts below affirmed the denial of PTD and Guthrie appeals to this court, which affirms.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the commission abused its discretion in denying PTD | Guthrie contends rehabilitation efforts show PTD. | Commission weighed factors; not require PTD given some ability to work. | No abuse; Guthrie capable of sedentary work. |
| Whether rehabilitation efforts must be considered favorably | Best-effort rehabilitation should support PTD. | SHO considered all factors; no punitive disregard for rehab. | Rehabilitation efforts were weighed but did not mandate PTD. |
| Whether deafness or job-market conditions were proper PTD factors | Deafness and poor job market should support PTD. | Disability cannot be based on non-injury-related conditions or market alone. | Not proper bases to grant PTD; only allowed conditions and vocational factors matter. |
Key Cases Cited
- State ex rel. Stephenson v. Indus. Comm., 31 Ohio St.3d 167 (1987) (PTD factors and Commission's expertise weighed)
- State ex rel. Ellis v. McGraw Edison Co., 66 Ohio St.3d 92 (1993) (Commission exclusive weight and credibility on vocational evidence)
- State ex rel. Jackson v. Indus. Comm., 79 Ohio St.3d 266 (1997) (Vocational factors integrated into PTD analysis)
- State ex rel. Waddle v. Indus. Comm., 67 Ohio St.3d 452 (1993) (Disability findings cannot rely on unrelated medical conditions)
- State ex rel. Nissin Brake Ohio, Inc. v. Indus. Comm., 127 Ohio St.3d 385 (2010) (Official reporter; relevance to PTD evaluation)
- State ex rel. George v. Indus. Comm., 130 Ohio St.3d 405 (2011) (Commission responsible for weighing vocational evidence)