State ex rel. Schmidt v. School Employees Retirement System

Summary

The Ohio Supreme Court affirmed the denial of Patricia Schmidt’s mandamus action seeking disability retirement benefits from the School Employees Retirement System. The court held that Schmidt could not obtain reversal because she challenged only one of the independent grounds for denial and had waived any challenge to the magistrate’s findings by failing to object.

Holdings

1. A judgment supported by multiple independent grounds is not subject to reversal when the appellant challenges only one of those grounds, even if the challenged rationale is incorrect.
2. A party waives appellate error concerning a magistrate's finding of fact or conclusion of law by failing to object to it before the trial court.

Questions Presented

1. Whether the denial of the writ should be reversed when Schmidt challenged only one of two independent grounds supporting the judgment.
2. Whether Schmidt waived any challenge to the briefing-compliance ground by failing to object to the magistrate's decision.

Disposition

affirmed