State ex rel. KeltanBW, Inc. v. Ohio Civ. Rights Comm.

Citations

• 2024 Ohio 2641

Syllabus

Prohibition, Ohio Civil Rights Commission, R.C. Chapter 4112 and general subject-matter jurisdiction to investigate employer discrimination, adequate remedy by appeal, voidable versus void judgment. The relator seeks a writ of prohibition on the basis that the Ohio Civil Rights Commission possesses no jurisdiction to investigate a discrimination claim based upon the facts pertinent to the claim of discrimination. Absent a patent and unambiguous lack of jurisdiction, a judicial entity or quasi-judicial entity having general jurisdiction of the subject matter of an action has the authority to determine its own jurisdiction. In addition, a party challenging a judicial entity or quasi-judicial entity's jurisdiction possesses an adequate remedy at law through an appeal from the court's holding that it has jurisdiction. Pursuant to R.C. Chapter 4112, the OCRC possesses the general subject-matter jurisdiction to investigate the claim that an employee, who is disabled, was unlawfully discriminated against by an employer for failing to accommodate her and provide time off for medical procedures. Also, when a specific action is within a judicial entity or quasi-judicial entity's subject-matter jurisdiction, any error in the exercise of that jurisdiction renders any judgment voidable, not void. Finally, when a judicial entity or quasi-judicial entity possesses basic subject-matter jurisdiction to act, and an appeal is available, a writ of prohibition will not issue.