In a significant legal decision, the Ohio Supreme Court recently addressed the rights of injured workers seeking workers’ compensation coverage. The case centered around Brian Caldwell, an employee of Whirlpool Corp., who sustained a right inguinal hernia while on the job in 2015. Whirlpool initially provided workers’ compensation, with the last payment in January 2017.
In December 2019, Caldwell sought additional compensation for related conditions stemming from his injury. Unfortunately, his claim was denied. After exhausting all avenues of appeal within the Industrial Commission, Caldwell took the matter to state court. He filed a complaint within the 60-day time limit following the commission’s final decision. However, he voluntarily dismissed the action in April 2021.
The jurisdiction challenge
Caldwell revived the case in April 2022, prompting Whirlpool to seek summary judgment. The company argued that Caldwell’s claim had expired due to the Industrial Commission’s five-year jurisdiction limit. According to this limit, the commission retains authority over a claim for five years after the last payment. By this logic, Caldwell’s claim would have become untimely as of January 2022. The trial court agreed with Whirlpool, leading to Caldwell’s appeal.
The court’s ruling
The Ohio Supreme Court’s ruling hinged on a crucial distinction. While the Industrial Commission’s jurisdiction limit applies to administrative matters, it does not impact workers’ compensation appeals in state courts. Instead, a separate statute—Ohio Revised Code Section 4123.512—governs appeals within 60 days of the commission’s final decision. Caldwell’s timely appeal ensured that the trial court had jurisdiction from that point forward.
Legal precedent and implications
The court emphasized that Caldwell had followed the proper procedures under R.C. 4123.512, securing his right to a day in court. The decision sets a precedent for injured workers across Ohio, reaffirming their ability to seek justice even when faced with jurisdictional challenges.
Reactions and next steps
Philip J. Fulton Law Office’s Chelsea F. Rubin represented Caldwell. She expressed satisfaction with the court’s unanimous application of workers’ compensation statutes. Still, Caldwell’s persistence paid off, and he will finally have the opportunity to present his case.