State ex rel. Stanadyne, Inc. v. Indus. Comm

In State ex rel. Stanadyne, Inc. v. Indus. Comm. (1984), 12 Ohio St. 3d 199, 12 Ohio B. 264, 466 N.E.2d 171, a truck driver was fatally injured in Indiana while working for his employer who did business in several states, including Ohio and Indiana. The administrator of the employee's estate filed a claim for workers' compensation benefits with the Industrial Commission of Ohio. Id. at 200. After initially denying the claim, the commission subsequently allowed it. The employer appealed, and the matter eventually reached the Ohio Supreme Court. Id. After narrowing its inquiry to the question of whether the decedent had "sufficient contacts" with Ohio so as to entitle his dependents to be eligible for death benefits under Ohio's workers' compensation law, the court found that it was "unable to conclude that the decedent's death was in any respect localized in Ohio." State ex rel. Stanadyne, Inc., 12 Ohio St.3d at 202. The Court added that "if the decedent had sought to receive coverage under the workers' compensation law of Ohio, then an agreement could have been executed in accordance with R.C. 4123.54." Id. at 203. After finding that no such agreement had been executed, the court concluded that the commission abused its discretion in allowing death benefits to decedent's dependents. Id.