Vacha v. City of North Ridgeville

Summary

The Supreme Court of Ohio held that R.C. 2744.09(B) may create an exception to political-subdivision immunity for an employee’s employer-intentional-tort claim. The court affirmed the denial of summary judgment to the City of North Ridgeville because the city had not established entitlement to immunity as a matter of law, while leaving determination of the required causal connection to the employment relationship for further proceedings.

Holdings

1. A civil action by an employee of a political subdivision alleging an intentional tort against the political-subdivision employer may qualify as a matter arising out of the employment relationship under R.C. 2744.09(B).
2. North Ridgeville was not entitled to summary judgment as a matter of law on Vacha's employer-intentional-tort claim because the city did not establish that political-subdivision immunity applied.

Questions Presented

1. Whether R.C. 2744.09(B) may apply to an employer-intentional-tort claim brought by an employee against a political subdivision.
2. Whether North Ridgeville was entitled to summary judgment on Vacha's employer-intentional-tort claim based on political-subdivision immunity.

Disposition

affirmed