State ex rel. Ohio Civil Service Employees Ass'n v. State Employment Relations Board

Summary

The Supreme Court of Ohio held that an amendment to R.C. 3318.31, which excluded Ohio School Facilities Commission employees from the state public-employee collective-bargaining law, violated the Ohio Constitution’s one-subject rule. The court also held that mandamus was an appropriate remedy because a declaratory judgment alone would not have required the State Employment Relations Board to reinstate the pending petitions.

Holdings

1. Mandamus was an appropriate vehicle because OCSEA sought to compel SERB, a public agency, to perform a specific statutory duty concerning specific petitions, and OCSEA lacked a plain and adequate remedy in the ordinary course of law.
2. Am.Sub.H.B. No. 405 violated the one-subject rule of Section 15(D), Article II of the Ohio Constitution insofar as it amended R.C. 3318.31 to exclude OSFC employees from the collective-bargaining process.
3. Because the amendment to R.C. 3318.31 was invalid, OCSEA had a clear legal right to reinstatement of its six petitions and SERB had a clear legal duty to reinstate them.

Questions Presented

1. Whether OCSEA could challenge SERB's dismissal of its petitions through an action for a writ of mandamus.
2. Whether OCSEA had a plain and adequate remedy in the ordinary course of law through a declaratory-judgment action.
3. Whether Am.Sub.H.B. No. 405 violated the one-subject rule in Section 15(D), Article II of the Ohio Constitution by including an amendment exempting OSFC employees from collective bargaining among numerous budget-related provisions.
4. Whether SERB had a clear legal duty to reinstate OCSEA's petitions after the amendment was invalidated.

Disposition

affirmed