Stetter v. R.J. Corman Derailment Services, L.L.C.

Summary

The Supreme Court of Ohio held that R.C. 2745.01, Ohio's employer intentional-tort statute as enacted by Am.H.B. No. 498, is facially constitutional. The court concluded that the statute does not violate the rights to a jury trial, a remedy, open courts, due course of law, or equal protection, and does not violate separation of powers or conflict with Sections 34 and 35, Article II of the Ohio Constitution. The court also held that the statute does not eliminate the common-law cause of action for an employer intentional tort.

Holdings

1. R.C. 2745.01 is facially constitutional and does not violate the Ohio Constitution's trial-by-jury, right-to-a-remedy, open-courts, due-course-of-law, equal-protection, or separation-of-powers provisions.
2. R.C. 2745.01 does not conflict with the legislative authority granted to the General Assembly by Sections 34 and 35, Article II of the Ohio Constitution.
3. R.C. 2745.01 does not eliminate the common-law cause of action for an employer intentional tort, although it significantly limits recovery by requiring specific or deliberate intent to injure, subject to the statutory presumption for deliberate safety-guard removal or hazardous-substance misrepresentation.
4. R.C. 2745.01 does not violate Section 16, Article I of the Ohio Constitution because it preserves meaningful remedies for deliberate employer intentional torts and workers' compensation remedies for injuries falling short of the statutory standard.
5. R.C. 2745.01 does not violate the right to trial by jury under Section 5, Article I of the Ohio Constitution.
6. R.C. 2745.01 does not violate the due-course-of-law provision of Section 16, Article I because it survives rational-basis review.
7. R.C. 2745.01 does not violate the equal-protection provision of Section 2, Article I of the Ohio Constitution.
8. R.C. 2745.01 does not violate the separation-of-powers doctrine.

Questions Presented

1. Whether R.C. 2745.01, as enacted by Amended House Bill 498 and effective April 7, 2005, violates the Ohio Constitution's right to trial by jury.
2. Whether R.C. 2745.01 violates the Ohio Constitution's right to a remedy and right to open courts.
3. Whether R.C. 2745.01 violates the Ohio Constitution's due-course-of-law provision.
4. Whether R.C. 2745.01 violates the Ohio Constitution's equal-protection provision.
5. Whether R.C. 2745.01 violates the separation-of-powers doctrine.
6. Whether R.C. 2745.01 conflicts with the legislative authority granted to the General Assembly by Sections 34 and 35, Article II of the Ohio Constitution.
7. Whether R.C. 2745.01 eliminates the common-law cause of action for an employer intentional tort.

Disposition

other