State ex rel. Ritzie v. Reece-Campbell, Inc. (Slip Opinion), 146 Ohio St. 3d 259

Ritzie sustained an allowed lumbar injury in 1994 and returned to light duty in 1995; his 1994 claim was later amended to add several lumbar conditions in 2012.
He treated episodically with chiropractor Brian Nobbs beginning in 2007; the chiropractor described treatments as supportive and improving symptoms.
In 2009 Ritzie began new work and in 2010 suffered a compensable motor-vehicle injury; he received TTD for that claim and settled it on December 7, 2011 for $99,999 and did not return to work.
On July 12, 2012 the BWC allowed additional lumbar conditions in the 1994 claim; three weeks later Ritzie sought TTD beginning December 8, 2011 (the day after his 2010 settlement), based on the newly allowed 1994 conditions.
The Industrial Commission denied TTD, finding no persuasive medical evidence that the 1994-allowed conditions rendered him temporarily and totally disabled as of December 8, 2011; the commission relied on Nobbs’s office notes showing improvement and treatment described as episodic/supportive.
The Tenth District denied mandamus; the Supreme Court of Ohio affirmed, holding the commission articulated a reasonable basis to reject Nobbs’s opinion and did not abuse discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Commission erred by denying TTD beginning Dec. 8, 2011	Ritzie: cumulative evidence (uncontroverted medical records, treatment authorizations, newly allowed conditions) shows he could not return to his former duties and proves TTD without needing the magic phrase “temporary total disability.”	Commission: medical records (esp. Dr. Nobbs’s notes) do not show deterioration or an opinion that the 1994 conditions caused TTD as of Dec. 8, 2011; allowed conditions alone do not automatically create a new TTD period.	Affirmed: Commission did not abuse discretion; it gave a reasonable basis for finding Nobbs’s opinion unpersuasive and claimant failed to meet burden to show TTD beginning Dec. 8, 2011.

State ex rel. Floyd v. Formica Corp., 140 Ohio St.3d 260 (2013) (claimant must show medical inability to work from allowed conditions to receive TTD)
State ex rel. McCoy v. Dedicated Transport, Inc., 97 Ohio St.3d 25 (2002) (same principle regarding causation and TTD)
State ex rel. Metz v. GTC, Inc., 142 Ohio St.3d 359 (2015) (Commission must state evidence relied upon and briefly explain reasoning)
State ex rel. Eberhardt v. Flxible Corp., 70 Ohio St.3d 649 (1994) (Commission must articulate a reasonable basis to reject a physician’s finding)
State ex rel. Pavis v. Gen. Motors Corp., 65 Ohio St.3d 30 (1992) (same standard for rejecting medical evidence)
State ex rel. Hutton v. Indus. Comm., 29 Ohio St.2d 9 (1972) (Commission may not arbitrarily reject competent medical proof)
State ex rel. Teece v. Indus. Comm., 68 Ohio St.2d 165 (1981) (Commission evaluates weight and credibility of evidence)
State ex rel. Pass v. C.S.T. Extraction Co., 74 Ohio St.3d 373 (1996) (deference to Commission’s disability evaluations)