Campbell v. Dept. of Job & Family Servs.

Citations

• 2020 Ohio 298

Syllabus

After an administrative appeal was filed in the trial court, the appellant, who was a resident of a nursing home, died a Civ.R. 25 motion to substitute the executor of the estate for the deceased appellant was properly and timely filed, and the trial court erred by not granting the motion. The trial court also erred in concluding that it lacked jurisdiction over the administrative appeal from a decision of the Ohio Department of Job and Family Services (ODJFS), because an amended notice of appeal which substituted the administrator of the estate for the original appellant/decedent was not filed. But the trial court did not err by concluding, in the alternative, that the ODJFS properly denied a state hearing on the appellant's application for Medicaid benefits. The decedent's health care power of attorney was for health care decisions, not financial decisions, and did not authorize her agent to designate a representative for the purpose of a Medicaid coverage appeal. Judgment reversed and remanded for the trial court to enter judgment in favor of ODJFS for the reasons stated in the opinion.