In Hughes v. Hughes Enterprises, Inc., Paulding App. No. 11-2000-11, 2000 Ohio 1937, the Third Appellate District found that there was no genuine issue of material fact as to Hughes, a self-employed chiropractor's status as a fixed-situs employee. Hughes argued that he used his home office to write patient reports. The court stated, "we are unpersuaded by Hughes' argument that simply writing reports at home should somehow entitle him to participate in the fund." Id.