Background
Keith Love sued the Hamilton County Board of Commissioners under 42 U.S.C. § 1983 after the Hamilton County Department of Job and Family Services substantiated a child-neglect allegation against him and placed information about him in the statewide child-abuse-and-neglect registry. Love alleged that the agency denied him Fourteenth Amendment due process and that the registry entry harmed his reputation and employment prospects.
Love received notice of the substantiated finding on April 6, 2023, appealed, and received a June 27, 2023 decision upholding the finding. He filed suit in August 2025, seeking declaratory and injunctive relief, expungement, and damages. The common pleas court dismissed, concluding it lacked jurisdiction under Ohio’s administrative-appeal statute and that the claim was untimely.
The Court’s Holding
The First District held that the trial court had jurisdiction over Love’s § 1983 claim. Love did not invoke R.C. 2506.01 to seek administrative review; instead, he asserted a federal civil-rights claim, which Ohio common pleas courts may hear under R.C. 2305.01 and the Ohio Constitution.
But the appellate court affirmed the dismissal because the claim was filed after Ohio’s two-year limitations period for § 1983 actions. Whether federal accrual law used an occurrence or discovery rule, Love’s claim accrued no later than June 27, 2023, when his administrative appeal was denied and the substantiated finding remained in place. Continuing consequences of registry placement did not restart the limitations period each day.
Key Takeaways
- Ohio common pleas courts have jurisdiction over § 1983 claims even when the claim relates to an agency child-neglect finding.
- A § 1983 due-process claim based on a substantiated registry finding accrued, at the latest, when Love’s administrative appeal was denied.
- Ongoing reputational and employment effects do not themselves create a continuing constitutional violation for limitations purposes.
Why It Matters
The decision distinguishes an improper administrative appeal from an independent federal civil-rights action. It also underscores that plaintiffs challenging allegedly deficient procedures must file within the limitations period after the alleged procedural deprivation is complete, even if the practical effects continue.