Ohio State Bd. of Pharmacy v. Poppe

In Ohio State Bd. of Pharmacy v. Poppe (1988), 48 Ohio App.3d 222, 549 N.E.2d 541, the court found error in the administrative agency's failure to issue a subpoena duces tecum as requested by the licensee. The court then determined that its "next task was to examine the prejudice to the licensee's case which resulted therefrom." Id. at 228. The court explained that "in doing so we are mindful that not all errors in an administrative proceeding, or a judicial proceeding for that matter, require reversal. Prejudice to the rights of the complaining party arising from the error complained of is essential to a reversal." Id. at 228-29, citing Lies, supra, at 204.