Clayton v. Ohio Bd. of Nursing (Slip Opinion)

{¶ 1} In this administrative appeal, we are asked to determine whether hearing examiners appointed by the Ohio Board of Nursing have the authority to quash or limit subpoenas requested in anticipation of disciplinary hearings. More specifically, we must determine whether in the disciplinary proceedings against plaintiff-appellant, Beverly Clayton, the hearing examiner’s decision to limit one of Clayton’s subpoenas caused reversible error. We hold that hearing examiners for the Ohio Board of Nursing have discretion to quash or limit subpoenas under appropriate circumstances and that the…