State ex rel. Sheller-Chiles v. Indus. Comm.
2014 Ohio 313
| Ohio Ct. App. | 2014Background
- Relator Sheller-Chiles sought a writ of mandamus to compel the Industrial Commission to grant permanent total disability (PTD) benefits.
- Claim allowed conditions include right shoulder injuries and associated disorders; left shoulder impairment noted.
- Dunne (orthopedic) opined light-work capacity with specific physical limitations; Chiarella (psychologist) opined capability for limited/part-time work with frequent breaks.
- Staff Hearing Officer (SHO) denied PTD, combining medical opinions to find some sustained part-time work in a light-duty, isolated environment.
- Magistrate Macke recommended granting the writ, finding Chiarella’s reports lacked explicit weekly hours to establish sustained part-time work.
- Court of Appeals conducted independent review, overruled the Commission’s objection, and granted the writ.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether part-time work can constitute sustained remunerative employment without hours per week. | Sheller-Chiles contends Chiarella’s vague limits cannot prove sustained part-time work. | Industrial Commission argues no explicit hours are required if overall capability for part-time work exists. | Yes, hours per week must be specified; magistrate prevailed that lack of hours invalidates part-time sustained work finding. |
| Whether the commissions' reliance on Chiarella's opinion supports PTD eligibility. | Chiarella's report shows ability to work with limitations, implying PTD could be overcome. | Chiarella’s opinion alone supports PTD only if it shows sustained work capacity with hours. | The commission erred by relying on Chiarella without specifying hours; not supported evidence of sustained part-time work. |
| Whether the combination of medical opinions can support a PTD denial when hours are unspecified. | Medical evidence supports some form of continued employment, undermining PTD. | Medical opinions together establish capability for light, part-time work in a restricted environment. | To uphold PTD denial, hours per week must be shown; failure renders the denial fatally flawed. |
Key Cases Cited
- State ex rel. Toth v. Indus. Comm., 80 Ohio St.3d 360 (1997) (part-time work can be sustained remunerative employment; hours matter case-by-case)
- State ex rel. DeSalvo v. May Co., 88 Ohio St.3d 231 (2000) (four-hour threshold guidance for sedentary work; limits on sitting/standing affect sustainability)