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State ex rel. Manor Care, Inc. v. Bur. of Workers' Comp. (Slip Opinion)

OhioNovember 25, 2020No. 2019-1046Cited 4 times
Defendant WinManor Care, Inc.
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Case Details

Judge(s)
Per Curiam
Status — whether other courts must follow this ruling
Published
Procedural Posture — the stage the case had reached
appeal

Related Laws

No specific laws identified for this ruling.

Outcome

The Ohio Supreme Court affirmed the lower court's denial of Manor Care's mandamus petition, holding that the relief fund is separate from PTD compensation obligations and cannot be used to offset an employer's underpayment of permanent-total-disability benefits.

Excerpt

Workers' compensation—To maintain the privilege of self-insurance, an employer must pay all compensation as required by Ohio's workers' compensation laws—An employer's obligation to reimburse Bureau of Workers' Compensation for relief-fund benefits is separate and distinct from its obligation to pay injured workers their awarded compensation—Relief-fund benefits may not be used to "offset" an incorrect payment of permanent-total-disability compensation—Court of appeals' judgment affirmed.

What This Ruling Means

**What Happened** Manor Care, a nursing home company that self-insures for workers' compensation, was involved in a dispute over how worker benefits should be paid. The company had underpaid an injured worker's permanent total disability benefits and tried to use money from Ohio's workers' compensation relief fund to cover the shortfall. Manor Care argued this "offsetting" method should be allowed to correct their payment mistake. **What the Court Decided** The Ohio Supreme Court ruled against Manor Care. The court determined that relief fund money and permanent disability payments are completely separate obligations that cannot be mixed together. Employers cannot use relief fund benefits to fix their own underpayments to injured workers. The court upheld a lower court decision that denied Manor Care's request. **Why This Matters for Workers** This ruling protects injured workers by ensuring they receive their full compensation as awarded. It prevents self-insured employers from taking shortcuts when they make payment errors. Workers can be confident that relief fund benefits remain separate protection, and employers cannot use those funds to cover up their own mistakes in paying disability benefits. This maintains the integrity of Ohio's workers' compensation system.

This summary was generated to explain the ruling in plain English and is not legal advice.

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