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Ohio High School Athletic Association v. Ruehlman

Supreme Court of Ohio

July 16, 2019

Ohio High School Athletic Association
Ruehlman, Judge.

          Submitted January 8, 2019

          In Prohibition.

          Keating, Muething & Klekamp, P.L.L., Joseph M. Callow Jr., Daniel E. Izenson, Bryce J. Yoder, and Taylor V. Trout; and Steven L. Craig, for relator.

          James W. Harper, Hamilton County Chief Assistant Prosecuting Attorney, and Andrea Neuwirth and Jay R. Wampler, Assistant Prosecuting Attorneys, for respondent.

          Ennis Britton Co., L.P.A., and Hollie F. Reedy, urging granting of the writ for amici curiae, Ohio School Boards Association, Buckeye Association of School Administrators, Ohio Association of School Business Officials, Ohio Interscholastic Athletic Administrators Association, and Ohio Association of Secondary School Administrators.

          DEWINE, J.

         {¶ 1} This is an action for a writ of prohibition. The Ohio High School Athletic Association ("OHSAA") seeks to prohibit Judge Robert Ruehlman from taking further action in a lawsuit that was filed against it in the Hamilton County Court of Common Pleas. Because Judge Ruehlman does not patently and unambiguously lack jurisdiction, we deny the writ.

         The OHSAA adopts new rules governing postseason competitions

         {¶ 2} The OHSAA regulates high-school sports competitions in Ohio. It is a voluntary, unincorporated, private organization whose members include more than 1, 600 public and private junior and senior high schools. Its functions include the regulation of postseason competitions.

         {¶ 3} Traditionally, the OHSAA assigned schools to different divisions for postseason-competition purposes based on the number of boys or girls enrolled at each school. But some OHSAA members complained that private schools were winning state championships at a disproportionate rate. An OHSAA committee concluded that one reason for the success of the private schools was their ability to draw students from a wider geographic area than public schools, whose students generally come from their districts.

         {¶ 4} In response to this concern, the OHSAA adopted "competitive-balance rules." These new rules use a formula to create an "adjusted enrollment count" to determine the division in which a school will be placed for postseason play for 8 of the 26 sports regulated by the association. Under the formula, a private high school is allowed a limited number of "feeder schools." The feeder schools are required to be from the same "system of education" (e.g., the Catholic Conference of Ohio or the Lutheran Schools of Ohio) and located within a single designated public-school-district attendance zone. If the private school enrolls a student-athlete who did not attend seventh and eighth grade in one of its designated feeder schools, then the school is penalized by having its adjusted enrollment count increased. Thus, for example, if a Catholic high school enrolls a basketball player who, for seventh and eighth grades, attended a Catholic school that is not one of that high school's designated feeder schools, one extra student is added to the school's enrollment count for purposes of determining the division in which the school's basketball team will compete. For public schools, the formula is based on whether the student and at least one of his parents reside within the school district.

         Judge Ruehlman grants a temporary restraining order

         {¶ 5} Roger Bacon High School and the athletic conference of which it is a member, the Greater Catholic League Coed ("GCL Coed"), filed a lawsuit to enjoin application of the competitive-balance rules against GCL Coed schools. The plaintiffs' worry was that the Catholic feeder schools from which they traditionally received students did not all fall within a single designated public school attendance zone, and hence, under the new rules they would be penalized for enrolling student-athletes from some of those schools. Judge Ruehlman held that the OHSAA had acted arbitrarily and capriciously by enforcing the rules against the GCL Coed "without ever considering whether a school's team was competitive in the first place and then penalizing the GCL Coeds [sic] schools for enrolling students from Catholic Feeder Schools that have historically sent students to the GCL Coed schools." And he issued a temporary restraining order ("TRO") enjoining the application of the adjusted enrollment formula in cases where the high school enrolled a student who attended seventh and eighth grades at one of its traditional "Catholic Feeder Schools." The OHSAA responded by filing an original action in this court seeking a writ of prohibition to prevent Judge Ruehlman from taking further action in the case and to order him to vacate the TRO. After the OHSAA filed its lawsuit, we stayed Judge Ruehlman's TRO pending the resolution of this case. We now must decide whether to grant the writ.

         We deny the OHSAA 's request for a writ of prohibition

         {¶ 6} We reserve the use of extraordinary writs for rare cases. A "writ of prohibition is an extraordinary remedy that is granted in limited circumstances with great caution and restraint." State ex rel. Corn v. Russo, 90 Ohio St.3d 551, 554, 740 N.E.2d 265 (2001). "In the absence of a patent and unambiguous lack of jurisdiction, a court having general subject-matter jurisdiction can determine its own jurisdiction, and a party contesting that jurisdiction has an adequate remedy by appeal." State ex rel. Plant v. Cosgrove, 119 Ohio St.3d 264, 2008-Ohio-3838, 893 N.E.2d 485, ¶ 5. The OHSAA does not contend that it lacks an adequate remedy at law but, rather, seeks to rely on the narrow exception that allows us to issue a writ of prohibition "where there is a patent and unambiguous lack of subject matter jurisdiction," State ex rel. Ohio Edison Co. v. Parrott, 73 Ohio St.3d 705, 707, 654 N.E.2d 106 (1995).

         {¶ 7} Here, Judge Ruehlman plainly had subject-matter jurisdiction over the lawsuit filed against the OHSAA. Under our Constitution, a court of common pleas has "original jurisdiction over all justiciable matters and such powers of review of proceedings of administrative officers and agencies as may be provided by law." Ohio Constitution, Article IV, Section 4(B). A common pleas court is a "court of general jurisdiction, with subject-matter jurisdiction that extends to 'all matters at law and in equity that are not denied to it.'" Bank of Am., N.A. v. Kuchta, 141 Ohio St.3d 75, 2014-Ohio-4275, 21 N.E.3d 1040, ¶ 20, quoting Saxton v. Seiberling, 48 Ohio St. 554, 558-559, 29 N.E. 179 (1891). And we have interpreted Article IV s mandate that the courts of common pleas have jurisdiction "as may be provided by law" to mean that "[t]he general subject matter jurisdiction of Ohio courts of common pleas is defined entirely by statute" (emphasis added), State v. Wilson, 73 Ohio St.3d 40, 42, 652 N.E.2d 196 (1995).

         {¶ 8} With limited exceptions, R.C. 2305.01 grants the courts of common pleas subject-matter jurisdiction over "all civil cases in which the sum or matter in dispute exceeds the exclusive original jurisdiction of county courts." This differentiates the courts of common pleas from other courts that (again, by statute) have more limited grants of jurisdiction. See, e.g., State ex rel. Goldberg v. Mahoning Cty. Probate Court, 93 Ohio St.3d 160, 162, 753 N.E.2d 192 (2001) ("Probate courts are courts of limited jurisdiction, and probate proceedings are consequently restricted to actions permitted by statute and the Ohio Constitution").

         {¶ 9} Because of R.C. 2305.01's general grant of jurisdiction, a court of common pleas has jurisdiction over any case in which the matter in controversy exceeds the jurisdictional limit unless some statute takes that jurisdiction away. See State ex rel. Ohio Co. v. Maschari, 51 Ohio St.3d 18, 20, 553 N.E.2d 1356 (1990). Thus, when we have found that a court of common pleas patently and unambiguously lacks jurisdiction, it is almost always because a statute explicitly removed that jurisdiction.[1] See State ex rel. Albright v. Delaware Cty. Court of Common Pleas, 60 Ohio St.3d 40, 42, 572 N.E.2d 1387 (1991) (noting that under R.C. 709, exclusive jurisdiction to consider annexation matters rests with the court of common pleas in the county in which the hearing on the annexation petition takes place); State ex rel. Taft-O'Connor '98 v. Franklin Cty. Court of Common Pleas, 83 Ohio St.3d 487, 488-489, 700 N.E.2d 1232 (1998) (noting that under R.C. 3517.151(A), the "Ohio Elections Commission has exclusive jurisdiction over the claims of fraudulent and false statements"); State ex rel. Wilkinson v. Reed, 99 Ohio St.3d 106, 2003-Ohio-2506, 789 N.E.2d 203, ¶ 16, 21 (noting that under R.C. Chapter 4117, the State Employment Relations Board has exclusive jurisdiction over charges of unfair labor practices); State ex rel. Dir., Ohio Dept. of Agriculture v. Forchione, 148 Ohio St.3d 105, 2016-Ohio-3049, 69 N.E.3d 636, ¶ 29 (holding that R.C. 935.20(A) gives the Ohio Department of Agriculture the exclusive authority to order the quarantine or transfer of dangerous wild animals).

         {¶ 10} The OHSAA asks us to depart from these principles. It points to no statute denying subject-matter jurisdiction to the court of common pleas but, instead, asks us to grant a writ of prohibition based on a few occurrences of the word "jurisdiction" in two of our previous decisions. See State ex rel. Ohio High School Athletic Assn. v. Judges of Stark Cty. Court of Common Pleas, 173 Ohio St. 239, 250, 181 N.E.2d 261 (1962) ("Stark Cty. Judges") ("Under these circumstances, a court has no jurisdiction to enjoin the association or its members from enforcing this lawfully imposed penalty"); Lough v. Varsity Bowl, Inc., 16 Ohio St.2d 153, 154, 243 N.E.2d 61 (1968) (noting that the dispute "concerns the jurisdictional requirements for judicial review of the decision of a voluntary association").

         {¶ 11} In relying on these cases, the OHSAA fails to account for the varying manners in which the word "jurisdiction" has been used. See Kuchta, 141 Ohio St.3d 75, 2014-Ohio-4275, 21 N.E.3d 1040, at ¶ 18; Pratts v. Hurley, 102 Ohio St.3d 81, 2004-Ohio-1980, 806 N.E.2d 992, ¶ 33." 'Jurisdiction,' it has been observed, 'is a word of many, too many, meanings.'" Steel Co. v. Citizens for a Better Environment, 523 U.S. 83, 90, 118 S.Ct. 1003, 140 L.Ed.2d 210 (1998), quoting United States v. Vanness, 85 F.3d 661, 663 (D.C.Cir.1996), fn. 2. The "unspecified use of this polysemic word" often "lead[s] to confusion and has repeatedly required clarification as to which type of 'jurisdiction' is applicable in various legal analyses." Kuchta at ¶ 18. Thus, we have made clear, "There is a distinction between a court that lacks subject-matter jurisdiction over a case and a court that improperly exercises that subject-matter jurisdiction once conferred upon it." Pratts at ¶ 10.

         {¶ 12} The cases relied upon by the OHSAA announced not a rule of subject-matter jurisdiction but, rather, a substantive legal rule of noninterference with the decisions of voluntary organizations absent special circumstances or a permissive statute. They are best understood as using the term "jurisdiction" in the loose sense of a court's legal authority to grant the relief sought by the plaintiff based upon the conduct alleged.

         {¶ 13} The dissenting opinion disagrees with this characterization and reads Stark Cty. Judges, 173 Ohio St. 239, 181 N.E.2d 261, as making a claim about a court's subject-matter jurisdiction. Dissenting opinion at ¶ 36. We don't read that case that way. Indeed, such a reading would require us to ignore the constitutional and statutory grant of jurisdiction to the common pleas courts as well as vast swaths of case law. But insofar as the court in Stark Cty. Judges might be understood to have been making such a claim, it was doing so in error. As the United States Supreme Court has noted, such "drive-by jurisdictional rulings" resulting from a lack of precision in distinguishing between substantive law that limits a court's legal authority ...

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