[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
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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:
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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.
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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.
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Case No. 2026-L-0014