Manansingh v. United States of America

The trial court correctly confined its review to the record as filed by the Ohio Civil Rights Commission (OCRC) related to a charge of discrimination against appellant's former employer. The trial court did not err in applying the "unlawful, irrational, arbitrary or capricious" standard of review to the OCRC's decision to dismiss appellant's charge of discrimination or in finding that the OCRC's decision was not unlawful, irrational, arbitrary or capricious. Appellant asserted that an unlawful discriminatory practice occurred on December 21, 2017, when her former employer filed a brief in a prior case asserting that further review of appellant's termination was moot because her teaching license had been permanently revoked. The OCRC determined that the former employer's argument was not a "discrete and new act of harm" to appellant over which it had jurisdiction, and the trial court correctly found sufficient justification for the OCRC's decision not to conduct an evidentiary hearing or issue a complaint. Judgment affirmed.

The trial court did not abuse its discretion in overruling Appellant's motion to amend her complaint, to include facts regarding her PTSD diagnosis and claims of racial and disability discrimination, eight months after she filed her administrative appeal from the termination of her teaching contract. The trial court did not consider Appellant's prior discipline at another school when determining that she was subject to termination, and Appellant was not denied due process. The trial court did not abuse its discretion in finding that Appellant's failure to enter third quarter final grades was good and just cause for termination. Judgment affirmed.