R.C. 4123.519 Interpretation
In Stanley v. Mayfield (Aug. 2, 1990), Mahoning App. No. 89 CA 184, 1990 Ohio App, the court found that the trial court did not have jurisdiction under R.C. 4123.519 to rule on claimant's appeal of a decision by the Industrial Commission denying his claim for benefits, because claimant's injury occurred outside the state and there was no evidence that the contract of employment between claimant and his employer was entered into by the claimant and his employer in the county in which claimant brought the appeal.
However, since Stanley was decided, R.C. 4123.519, which was renumbered as R.C. 4123.512, has been amended to allow a trial court in which an action has been mistakenly filed, to transfer the action to the court of a county having jurisdiction, and the provisions of R.C. 4123.519(A) (now contained in R.C. 4123.512A) at issue in Stanley are no longer viewed as jurisdictional requirements, but rather as venue provisions. Mays v. Kroger Co. (1998), 129 Ohio App.3d 159, 163, 717 N.E.2d 398. Id.