Robinson v. Ohio Dept. of Job & Family Servs.

Citations

• 2026 Ohio 2090

Syllabus

Unemployment compensation; administrative appeal; subject-matter jurisdiction; untimely appeal; equitable tolling; jurisdictional deadline; continuing-violation doctrine; Americans with Disabilities Act; reasonable accommodation; equitable estoppel; waiver; pro se litigant; mootness; R.C. 1.14; R.C. 4141.01(A)(1); R.C. 4141.281(D)(9); R.C. 4141.282; R.C. 4141.282(A); R.C. 4141.282(C); R.C. 4141.282(I); Civ.R. 6(A); Civ.R. 6(D); App.R. 12(A)(1)(c); App.R. 12(A)(2); App.R. 16(A)(7). Judgment affirmed. The common pleas court lacked subject-matter jurisdiction over an unemployment compensation administrative appeal filed four days after the 30-day deadline in R.C. 4141.282(A). The deadline is a jurisdictional prerequisite to invoking the common pleas court's appellate jurisdiction, not an ordinary limitations period subject to equitable tolling. The statutory deadline extensions specified in R.C. 4141.281(D)(9) did not apply because the deadline fell on a Friday and the appellant did not claim she failed to receive the Review Commission decision within the 30-day appeal period. Arguments regarding equitable tolling, continuing violation, Americans with Disabilities Act accommodations, grace-period computation under applicable civil rules, and equitable estoppel were either waived or lacked merit. Because the appeal was untimely, the appellant's merits-based challenges to the Review Commission's decision and her additional claims against the Ohio Department of Jobs and Family Services, Cleveland State University, and the union were not considered by the trial court. Appellant's associated assignments of error were moot.