State ex rel. Maynard v. Medina Courthouse Steering Commt.
2020 Ohio 5562
Ohio Ct. App.2020Background
- Relator Dean Maynard sued the Medina Courthouse Steering Committee and several officials under R.C. 121.22, alleging the committee met privately on June 6 and June 25, 2019, without public notice or minutes.
- He sought declaratory and injunctive relief, invalidation of actions taken based on those meetings, statutory forfeitures, and costs/fees.
- Respondents moved for judgment on the pleadings under Civ.R. 12(C); some defendants attached email exhibits to their answers.
- The trial court granted judgment for respondents, finding (1) an email showed a private firm (BCI) created the Steering Committee so it was not a public body subject to R.C. 121.22, and (2) the committee and its members were non sui juris and not proper defendants.
- The Ninth District reversed: construing Maynard’s complaint as true for purposes of Civ.R. 12(C), the court held his allegations could state a claim under R.C. 121.22 and that individual members were properly joined; the cost issue was rendered moot by reversal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether judgment on the pleadings was proper | Maynard: court relied on facts outside pleadings and ignored his allegations; pleadings, if true, state a claim | Respondents: attached documents show committee was created by private BCI and only received information, so no public-body meeting | Court: Error — on 12(C) allegations must be taken as true; pleadings could support an R.C. 121.22 claim, so judgment on pleadings improper |
| Whether the Steering Committee is a "public body" under R.C. 121.22 | Maynard: committee is a subcommittee of the County Commissioners and thus a public body subject to the Open Meetings Act | Respondents: committee was created by private BCI and therefore not a public body; June gatherings were only informational | Court: At pleading stage, must accept Maynard’s allegation that committee was a public-body subcommittee; claim survives dismissal |
| Whether the committee and its members are sui juris / proper defendants | Maynard: statute authorizes suits against public bodies and individual members may be sued in official capacity | Respondents: committee (and members) are non sui juris and cannot be sued absent statutory authorization | Court: Error — even if the body itself were not independently sui juris, suing members in their official capacities is effectively a suit against the public body and the individuals were properly joined |
| Trial-court order taxing court costs against plaintiff | Maynard: trial court imposed unauthorized costs and fees | Respondents: (implicit) costs appropriate after dismissal | Court: Moot — reversal of judgment on pleadings renders cost issue moot |
Key Cases Cited
- State ex rel. Midwest Pride IV, Inc. v. Pontious, 75 Ohio St.3d 565, 664 N.E.2d 931 (Ohio 1996) (standard for Civ.R. 12(C): construe complaint in favor of nonmovant and dismiss only if no set of facts would entitle relief)
- Whaley v. Franklin County Bd. of Commrs., 92 Ohio St.3d 574, 752 N.E.2d 267 (Ohio 2001) (Civ.R. 12(C) can be treated as belated Civ.R. 12(B)(6) motion)
- State ex rel. Leneghan v. Husted, 154 Ohio St.3d 60, 110 N.E.3d 1275 (Ohio 2018) (interpretation of Civ.R. 10(C) and what qualifies as a “written instrument” attached to a pleading)
- State ex rel. American Civil Liberties Union of Ohio, Inc. v. Cuyahoga Cty. Bd. of Commrs., 128 Ohio St.3d 256, 943 N.E.2d 553 (Ohio 2011) (definitional discussion of “committee” and statutory construction of R.C. 121.22)
- Mollette v. Portsmouth City Council, 169 Ohio App.3d 557, 863 N.E.2d 1092 (Ohio App. 2006) (held that, absent statutory authority, certain municipal bodies may be non sui juris and not separately suable)
- City of Cuyahoga Falls v. Robart, 58 Ohio St.3d 1, 567 N.E.2d 987 (Ohio 1991) (principle that municipal legislative bodies are not sui juris absent statute)
- Burnside v. Leimbach, 71 Ohio App.3d 399, 594 N.E.2d 60 (Ohio App. 1991) (judgment on the pleadings appropriate only where no material factual issues exist)
- Maddox v. Greene County Children Servs. Bd. of Dirs., 12 N.E.3d 476 (Ohio App. 2014) (suit against official in official capacity is effectively a suit against the public body)