State ex rel. Woodman v. Ohio Pub. Emps. Retirement Sys. (Slip Opinion), 144 Ohio St. 3d 367

Background

Raeanne Woodman, a former Ohio State University office assistant with long-term neurological injuries (pontine hemorrhage, right-sided weakness, right-eye vision loss, hearing loss, wheelchair-bound), applied for OPERS disability retirement in Oct. 2011.
She alleged progressive worsening, especially hearing problems interfering with work in noisy office settings; submitted treating physician Dr. Mack’s report describing permanent deficits.
OPERS required an independent exam by Dr. Robert Shadel, who concluded Woodman was not disabled, finding adequate hearing in the exam room and that deficits were not disabling. MMRO reviewers recommended denial; OPERS denied benefits.
On appeal Woodman submitted audiologic testing from Dr. Gerald Steiman showing moderate-to-severe right-sided sensorineural loss with poor speech discrimination; Steiman opined she could not perform receptionist duties but did not identify which impairment was dispositive.
The Tenth District granted a writ of mandamus, concluding OPERS’ medical reviewers relied on inadequate (quiet-room) testing and that there was no evidence supporting OPERS’ finding; the Supreme Court of Ohio reversed, holding the court of appeals improperly reweighed medical evidence.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether OPERS abused its discretion in denying disability benefits	Woodman: her worsening hearing (and other deficits) prevent performance; treating/testing evidence shows inability to work in real-world noisy office	OPERS: its reviewing physician’s opinion (Dr. Shadel) constitutes some evidence that her impairments are not disabling	Court: OPERS did not abuse discretion; some evidence (Shadel) supported denial and the appeals court improperly reweighed credibility/weight of medical evidence
Whether the court of appeals could reject Dr. Shadel’s testing protocol sua sponte	Woodman: testing under ideal conditions failed to capture workplace hearing limitations; court may consider adequacy of evidence	OPERS: appellate court may not substitute its judgment or raise new evidentiary defects sua sponte to overturn agency	Court: appellate court abused discretion by substituting judgment; board decides weight/credibility; reversal required
Whether internal inconsistency in Dr. Shadel’s report vitiates it as "some evidence"	Woodman: Shadel’s report is internally inconsistent and thus cannot support denial	OPERS: purported inconsistency is a misreading; Shadel acknowledged impairments but found them non-disabling	Court: report was not internally contradictory about disabling severity; it qualified as "some evidence"
Appropriate remedy if testing was inadequate	Woodman: remand or grant benefits because no evidence supports return to work	OPERS: if testing inadequate, remand for further proceedings rather than mandamus grant	Court: did not reach remedy question because it found some evidence supported OPERS; reversed court of appeals’ writ grant

Key Cases Cited

State ex rel. Pipoly v. State Teachers Retirement Sys., 95 Ohio St.3d 327 (2002) (mandamus proper where no statutory appeal exists for correcting administrative abuse of discretion)
State ex rel. Cydrus v. Ohio Pub. Emps. Retirement Sys., 127 Ohio St.3d 257 (2010) (mandamus available for disability-retirement decisions)
State ex rel. Shisler v. Ohio Pub. Emps. Retirement Sys., 122 Ohio St.3d 148 (2009) (abuse of discretion standard; reviewing courts must not reweigh evidence)
State ex rel. Nese v. State Teachers Retirement Bd. of Ohio, 136 Ohio St.3d 103 (2013) (board abuses discretion only if decision lacks some evidentiary support)
State ex rel. Schaengold v. Ohio Pub. Emps. Retirement Sys., 114 Ohio St.3d 147 (2007) (same standard: some evidence required to deny benefits)
State ex rel. Hart v. Indus. Comm., 66 Ohio St.3d 95 (1993) (administrative bodies assess weight and credibility; courts should not reweigh)
State ex rel. Wyrick v. Indus. Comm., 138 Ohio St.3d 465 (2014) (internally inconsistent medical opinions cannot supply "some evidence")
State ex rel. Am. Std., Inc. v. Boehler, 99 Ohio St.3d 39 (2003) (existence of conflicting evidence does not nullify agency decision if some evidence supports it)