State ex rel. Hanna v. Industrial Commission

We are asked to preliminarily determine whether the commission’s permanent total disability order satisfies Noll. If it does not, we must further decide whether to: (1) return the cause to the commission for further explanation per Noll or (2) simply order the commission to grant permanent total disability compensation pursuant to State ex rel. Gay v. Mihm (1994), 68 Ohio St.3d 315, 626 N.E.2d 666. We favor the first alternative.

As is increasingly the case, the commission’s order combines vocational factors that are both favorable and unfavorable without explaining how these factors make…