Cristino v. Ohio Bureau of Workers' Compensation

Summary

The Ohio Supreme Court held that a restitution claim seeking the difference between a lump-sum workers’ compensation payment and the alleged actual present value of permanent total disability benefits was based on an agreement with the Ohio Bureau of Workers’ Compensation. Because the claim sought money allegedly due under that agreement, it was a legal rather than equitable restitution claim. The court concluded that the Ohio Court of Claims had exclusive subject-matter jurisdiction and reversed the judgment of the Eighth District Court of Appeals.

Holdings

1. A claim against the state for money due under a contract is not an equitable claim for restitution and must be brought in the Ohio Court of Claims.
2. The claim did not enforce a statutory right to permanent-total-disability benefits because Cristino sought a lump-sum payment under his agreement after relinquishing the statutory right to periodic payments, and no statute entitled him to the requested lump sum.

Questions Presented

1. Whether Cristino's restitution claim sought equitable relief within the jurisdiction of the courts of common pleas under R.C. 2743.03(A)(2), or legal monetary relief within the exclusive jurisdiction of the Ohio Court of Claims under R.C. 2743.03(A)(1).
2. Whether the claim was based on a statutory entitlement to permanent-total-disability benefits or on an agreement with the Bureau concerning a lump-sum payment.

Disposition

reversed