State ex rel. Ohio Bur. of Workers' Comp. v. O'Donnell, 2023 Ohio 428

In 2013 the cities of Cleveland and Parma sued the Ohio Bureau of Workers’ Compensation (BWC) claiming BWC’s premium-calculation method overcharged non-group-rated employers; Parma brought a class action.
In 2020 this court held Cleveland’s restitution claim sounded in law and therefore fell within the Court of Claims’ exclusive jurisdiction; Parma’s earlier suit was dismissed without prejudice for lack of jurisdiction.
In 2021 Parma refiled in Cuyahoga County Common Pleas Court seeking declaratory and injunctive relief to compel refunds, and simultaneously filed a damages action in the Court of Claims; Judge O’Donnell denied BWC’s motion to dismiss the common-pleas action.
BWC filed an original action in the Ohio Supreme Court seeking writs of prohibition (to stop the common-pleas court from exercising jurisdiction) and mandamus (to dismiss the underlying case), arguing Parma’s claims are legal in nature (refunds) and belong in the Court of Claims.
The Supreme Court analyzed whether Parma’s requests for declaratory and injunctive relief were, in substance, a legal claim for money damages traceable only to general funds that had become commingled, and concluded Parma’s claim sounds in law and must proceed in the Court of Claims.
The Court granted both writs: prohibition to prevent further exercise of jurisdiction by Judge O’Donnell and mandamus ordering dismissal of the underlying common-pleas case.

Issue	Parma's Argument	BWC's Argument	Held
Does the Court of Claims Act (R.C. 2743.03(A)) bar the common-pleas court from hearing Parma’s suit?	Parma: Seeks only declaratory and injunctive relief, so common-pleas jurisdiction preserved.	BWC: Parma’s true objective is refunds (money), so claim sounds in law and belongs in Court of Claims.	Held: Claim sounds in law; Court of Claims has exclusive jurisdiction; common pleas lacks jurisdiction.
Can Parma’s labeling as declaratory/injunctive defeat Court of Claims jurisdiction?	Parma: Labels control; equitable remedies are sought.	BWC: Substance controls; artful pleading cannot convert a legal claim into equitable relief.	Held: Substance over labels; labels ignored for jurisdictional analysis.
Is prohibition appropriate given an adequate remedy by appeal and the trial court’s power to decide jurisdiction?	Judge O’Donnell/Parma: Adequate remedy exists by appeal; common pleas may determine its own jurisdiction.	BWC: When lack of jurisdiction is patent and unambiguous, prohibition is appropriate and no appeal suffices.	Held: Prohibition proper because the lack of jurisdiction is patent and unambiguous.
Is mandamus proper to compel dismissal of the underlying case?	Judge O’Donnell/Parma: Bureau has adequate remedy by appeal, so mandamus improper.	BWC: Mandamus is appropriate to correct prior unauthorized proceedings when jurisdiction is patently lacking.	Held: Mandamus granted; Judge O’Donnell must dismiss the underlying case.

Cleveland v. Ohio Bur. of Workers’ Comp., 152 N.E.3d 172 (Ohio 2020) (claim for refunds sounded in law because funds were commingled; Court of Claims exclusive jurisdiction)
Montanile v. Natl. Elevator Industry Health Benefit Plan Bd. of Trustees, 577 U.S. 136 (2016) (equitable relief requires specifically identifiable funds that remain in defendant’s possession)
Great-West Life & Annuity Ins. Co. v. Knudson, 534 U.S. 204 (2002) (actions seeking to compel payment of money are generally legal claims for damages)
Cirino v. Ohio Bur. of Workers’ Comp., 106 N.E.3d 41 (Ohio 2018) (concurring-in-judgment observation that payment claims can be artfully pled as injunctions or declarations)
Ohio Hosp. Assn. v. Ohio Dept. of Human Servs., 579 N.E.2d 695 (Ohio 1991) (Court of Claims has exclusive jurisdiction over legal claims joined with declaratory relief arising from same circumstances)
State ex rel. Sapp v. Franklin Cty. Court of Appeals, 889 N.E.2d 500 (Ohio 2008) (when an inferior court patently lacks jurisdiction, prohibition and mandamus will issue to prevent and correct unauthorized proceedings)