State ex rel. Seabolt v. State Hwy. Patrol Retirement Sys. (Slip Opinion)
129 N.E.3d 379
Ohio2019Background
- Benjamin Seabolt, an Ohio state trooper since 2007, developed chronic lower-back problems (L5-S1 disc bulge/collapse) and sought permanent total disability retirement from the State Highway Patrol Retirement System (HPRS), claiming onset Dec. 22, 2015.
- Multiple treating physicians (chiropractor, osteopath, neurosurgeon) attributed Seabolt’s condition to occupational factors—primarily prolonged use of a 22–25 lb service/utility belt and repeated ingress/egress from cruisers; one treating surgeon recommended fusion.
- HPRS-appointed independent examiner (Dr. Griesser) diagnosed L5-S1 disc protrusion/degenerative disc disease and agreed Seabolt was totally and permanently disabled but did not opine on whether the disability arose in the line of duty.
- HPRS medical advisor (Dr. Tanner) reviewed records and concluded the condition was congenital/degenerative and preexisting, not substantially aggravated by duty; he found it “medically improbable” the belt caused the degenerative changes within nine years.
- The HPRS committee granted disability retirement but concluded the condition was not in the line of duty (reducing benefits); after reconsideration and additional records, the board reaffirmed the off-duty finding.
- Seabolt sought a writ of mandamus to compel HPRS to vacate the off-duty finding and grant in-line-of-duty disability. The Tenth District denied mandamus; the Ohio Supreme Court affirmed.
Issues
| Issue | Seabolt’s Argument | HPRS’s Argument | Held |
|---|---|---|---|
| Did the board abuse its discretion in finding Seabolt’s disability not in the line of duty? | Board disregarded credible medical evidence tying condition to belt; thus abused discretion. | Board had some evidence (medical-advisor report, MRI comparison, treating surgeon’s note that pain began without specific injury) supporting off-duty finding. | No abuse of discretion; some evidence supports board’s determination. |
| Is the “some evidence” standard met so mandamus is unavailable? | Contrary evidence from treating doctors shows causation, so decision was unreasonable. | Presence of contrary evidence immaterial if some evidence supports board; standard is deferential. | Some evidence existed (Dr. Tanner’s report and MRI findings); mandamus denied. |
| Was the board required to have the independent examiner (Dr. Griesser) state whether injury was in the line of duty under R.C. 5505.18(A)(3)? | Griesser’s failure to state line-of-duty means the board lacked required cause determination. | Griesser identified the medical cause (L5-S1 pathology); statute does not require stating mechanism or line-of-duty determination. | Court: Griesser satisfied the statute by diagnosing cause; not required to opine on mechanism/line-of-duty. |
| Could the court rely on Ohio Adm.Code 5505-3-02(E) (medical-advisor role) though adopted after examinations? | Magistrate improperly relied on a 2017 rule not effective at exam time. | Regardless of rule timing, board’s decision was supported by sufficient evidence. | Even if rule timing irrelevant, Seabolt failed to show board abused discretion; outcome stands. |
Key Cases Cited
- State ex rel. Grein v. Ohio State Hwy. Patrol Retirement Sys., 116 Ohio St.3d 344, 879 N.E.2d 195 (2007) (mandamus appropriate where no statutory appeal; some evidence standard for HPRS decisions)
- State ex rel. Woodman v. Ohio Pub. Emps. Retirement Sys., 144 Ohio St.3d 367, 43 N.E.3d 426 (2015) (mandamus will not lie if some evidence supports administrative decision)
- State ex rel. Nese v. State Teachers Retirement Bd. of Ohio, 136 Ohio St.3d 103, 991 N.E.2d 218 (2013) (explaining deferential review and some-evidence standard)
- State ex rel. Shisler v. Ohio Pub. Emps. Retirement Sys., 122 Ohio St.3d 148, 909 N.E.2d 610 (2009) (abuse-of-discretion standard defined)
- State ex rel. Waters v. Spaeth, 131 Ohio St.3d 55, 960 N.E.2d 452 (2012) (elements required to obtain writ of mandamus)
- Evans v. Natl. Life and Acc. Ins. Co., 22 Ohio St.3d 87, 488 N.E.2d 1247 (1986) (competent, credible evidence can rebut administrative presumptions)