Steinbrink v. Greenon Local School Dist.
2012 Ohio 1438
Ohio Ct. App.2012Background
- Plaintiff Steinbrink, a high school teacher and assistant football coach, sues Greenon Local School District and Lori Lytle for defamation, intentional infliction of emotional distress, and tortious interference with contract.
- Allegations stem from 2009 complaints about Steinbrink’s conduct with student-athletes; he was placed on administrative leave pending investigation.
- In June 2009, Lytle allegedly pressured Steinbrink to resign within 24 hours and warned of a board meeting to discuss his employment while promising full disclosure of the investigation results.
- The Board allegedly terminated Steinbrink’s supplemental coaching contract on June 6, 2009 after Lytle’s report; Steinbrink contends he was not timely notified and was deprived of promised disclosure.
- Defendants answered in January 2011 and moved for judgment on the pleadings under Civ.R. 12(C), arguing governmental immunity under R.C. Chapter 2744 and other defenses, including statute of limitations and qualified privilege.
- The trial court denied the Civ.R. 12(C) motion on June 17, 2011, and defendants appealed the ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Board immunity bars Steinbrink’s claims | Steinbrink argues R.C. 2744.09(B) creates an employment-related exception to immunity. | District and Lytle rely on general immunity and lack of employment-relationship exception under 2744.09(B). | R.C. 2744.09(B) creates an employment-relationship exception; overruled in favor of Steinbrink on immunity with Sampson v. CMHA guidance. |
| Whether Lytle is immune under R.C. 2744.03(A)(6) | Lytle’s acts in investigating and reporting were within scope and could be malicious, bad faith, or reckless. | Lytle acted within official duties; naked allegations lack factual enhancement. | Allegations support potential malicious/bad faith conduct; Lytle not shielded at Civ.R. 12(C) stage. |
| Whether 4123 workers’ compensation immunity applies to the claims | Defendants cannot invoke 4123 immunity to bar intentional tort and defamation claims. | Workers’ compensation immunity applies to injuries arising out of employment. | Samson and Blankenship principles reject 4123 as a blanket bar; certain intentional tort claims fall outside workers’ compensation. |
Key Cases Cited
- Blankenship v. Cincinnati Milacron Chemicals, Inc., 69 Ohio St.2d 608 (1982) (Blankenship permits an exception to immunity for intentional torts arising from employment context)
- Sampson v. Cuyahoga Metropolitan Housing Authority, Ohio St.3d, Slip Opinion No. 2012-Ohio-570 (2012) (recognizes R.C. 2744.09(B) may apply to intentional torts by employees of political subdivisions)
- Yeager v. Local Union 20, TCW&H, 6 Ohio St.3d 369 (1983) ( Yeager standard for Yeager public duty/intentional tort theories)
- Fleming v. AAS Service, Inc., 177 Ohio App.3d 778 (2008-Ohio-3908) (application of constitutional limits on workers’ compensation coverage for intentional torts)
- Johnson v. BP Chemicals, Inc., 85 Ohio St.3d 298 (1999) (constitutional constraints on extending workers’ compensation coverage)