Pivonka v. Corcoran

Citations

• 258 N.E.3d 559
• 2024 Ohio 5318

Syllabus

Class-action certification; unjust enrichment; reimbursement to Medicaid for personal-injury awards; subrogation under R.C. 5101.58; subject-matter jurisdiction in common pleas court or Court of Claims; legal relief; equitable relief. In this class action against the State, particularly the Ohio Department of Medicaid, if the allegations in the complaint are seen as legal claims then subject-matter jurisdiction lies in the Court of Claims. However, if the allegations in the complaint are seen as equitable claims, the common pleas court has subject-matter jurisdiction. Here, the allegations in the complaint concern wrongfully collected reimbursement funds paid back to the Ohio Department of Medicaid by Medicaid participants. The remedy concerns return of the funds to the participants. The issue: is this action claiming reimbursement a civil suit for money damages or an action in equity brought to correct unjust enrichment? The answer lies in whether the plaintiffs are seeking to recover from the defendant's general assets or specifically identified funds. Case dismissed and remanded to the trial court to develop the record with the jurisdictional facts needed for the court to determine whether this is a legal or equitable claim.