Phillips v. Unemp. Comp. Rev. Comm.

[Cite as Phillips v. Unemp. Comp. Rev. Comm., 2026-Ohio-3581.] IN THE COURT OF APPEALS OF OHIO ELEVENTH APPELLATE DISTRICT LAKE COUNTY MYRON R. PHILLIPS, CASE NO. 2026-L-0014 Appellant, Administrative Appeal from the - vs - Court of Common Pleas UNEMPLOYMENT COMPENSATION REVIEW COMMISSION, et al., Trial Court No. 2025 CV 002304 Appellees. OPINION AND JUDGMENT ENTRY Decided: September 14, 2026 Judgment: Reversed; remanded Myron R. Phillips, pro se, 8283 Brodie Boulevard, Mentor, OH 44060 (Appellant). Andy Wilson, Ohio Attorney General, State Office Tower, 30 East Broad Street, 16th Floor, Columbus, OH 43215, and Patrick MacQueeney, Assistant Attorney General, 615 West Superior Avenue, 11th Floor, Cleveland, OH 44113 (For Appellees). EUGENE A. LUCCI, J. {¶1} Appellant, Myron R. Phillips, appeals the judgment of the trial court denying his administrative appeal from a decision of the Unemployment Compensation Review Commission (“the review commission”). For the reasons that follow, we reverse the decision of the trial court and remand this matter for further proceedings consistent with this opinion. {¶2} On December 17, 2025, Phillips filed a “Notice of Appeal” pursuant to R.C. 4141.282 in the trial court, naming the “UNEMPLOYMENT COMPENSATION REVIEW COMMISSION OHIO DEPARTMENT OF JOB AND FAMILY SERVICES DIRECTOR, OHIO DEPARTMENT OF JOB AND FAMILY SERVICES” as the appellee. Phillips stated that he was appealing from the final decision of the review commission that was mailed on December 11, 2025. {¶3} On February 4, 2026, the trial court sua sponte issued an order finding that Phillips’s appeal failed to identify the decision from which he appealed in accordance with R.C. 4141.282(C). The court referenced case law holding that an appellant in an administrative appeal must strictly comply with statutory requirements to invoke the jurisdiction of the court of common pleas. See Zier v. Bur. of Unemp. Comp., 151 Ohio St. 123 (1949), paragraphs one and two of the syllabus, and Van De Hey v. Ashtabula Cty. Aud., 2023-Ohio-346, ¶ 28 (11th Dist.). The trial court then concluded that “[b]ecause the appellant failed to meet th[e] statutory requirement” of identifying the appealed decision, “his appeal is not well-taken and is hereby denied.” {¶4} Phillips timely appealed the trial court’s February 4, 2026 decision, and he now assigns two errors for our review. {¶5} In his first assigned error, Phillips argues: {¶6} “The trial court erred in dismissing Appellant's administrative appeal for failure to strictly comply with R.C. 4141.282(C) when the Notice of Appeal substantially complied with the statute and adequately identified the decision being appealed.” {¶7} With respect to an appeal to a common pleas court from a decision of the unemployment review commission, R.C. 4141.282(A) requires that the appeal be filed “within thirty days after written notice of the final decision” was sent to the interested parties. R.C. 4141.282(C) provides that “[t]he timely filing of the notice of appeal shall be the only act required to perfect the appeal and vest jurisdiction in the court. The notice of PAGE 2 OF 5 Case No. 2026-L-0014 appeal shall identify the decision appealed from.” Here, there is no dispute that the notice of appeal was timely filed in the trial court. Therefore, pursuant to the plain language of the statute, the trial court had jurisdiction over the appeal regardless of whether the notice of appeal sufficiently identified the appealed decision. See Pryor v. Dir., Dept. of Job & Family Servs., 2016-Ohio-2907, ¶ 14 (“The General Assembly has clearly stated in R.C. 4141.282(C) that the timely filing of the notice of appeal is the ‘only’ jurisdictional requirement for perfecting an appeal. The word ‘only’ means just that.”). {¶8} In its answer brief filed in this court, appellee, the Ohio Department of Job and Family Services (“ODJFS”), appears to agree that the trial court erred in dismissing the appeal on jurisdictional grounds. However, it contends that Phillips failed to name the proper parties as appellees pursuant to R.C. 4141.282(D) in his notice of appeal filed in the trial court. ODJFS maintains that this failure warrants dismissal, but, because the trial court dismissed the appeal sua sponte, ODJFS had not yet moved to dismiss on this basis. ODJFS maintains that the proper remedy is to remand this matter to the trial court for further proceedings. {¶9} We agree with the parties to the extent that they both contend that this matter was wrongfully dismissed on the basis of subject matter jurisdiction. We hold only that, because the notice of appeal was timely filed, the trial court’s jurisdiction was properly invoked. We express no opinion as to the sufficiency of identification of the appealed decision of the review commission or the merits of dismissal on the basis advanced by ODJFS. {¶10} Accordingly, Phillips’s first assigned error has merit. {¶11} In his second assigned error, Phillips contends: PAGE 3 OF 5 Case No. 2026-L-0014  {¶12} “The Review Commission abused its discretion in determining that Appellant lacked good cause for failing to appear at the scheduled hearing.” {¶13} Because the trial court dismissed this matter without reaching the merits, and our resolution of the first assigned error requires remand, consideration of the second assigned error pertaining to the merits of Phillips’s case is not ripe for our review, and we therefore do not address it. {¶14} The judgment of the trial court is reversed, and this matter is remanded to the trial court for further proceedings consistent with this opinion. MATT LYNCH, P.J., JOHN J. EKLUND, J., concur. PAGE 4 OF 5 Case No. 2026-L-0014  JUDGMENT ENTRY For the reasons stated in the opinion of this court, it is the judgment and order of this court that the judgment of the Lake County Court of Common Pleas is reversed, and this matter is remanded to the trial court for further proceedings consistent with the opinion. Costs to be taxed against appellees. JUDGE EUGENE A. LUCCI PRESIDING JUDGE MATT LYNCH, concurs JUDGE JOHN J. EKLUND, concurs THIS DOCUMENT CONSTITUTES A FINAL JUDGMENT ENTRY A certified copy of this opinion and judgment entry shall constitute the mandate pursuant to Rule 27 of the Ohio Rules of Appellate Procedure. PAGE 5 OF 5 Case No. 2026-L-0014