Tony Moody v. Ohio Department of Mental Health and Addiction Services
1. Whether the cumulative errors in applying established
antiretaliation standards —specifically the misapplication of the
McDonnell Douglas burden-shifting framework and the failure to
consider temporal proximity and disparate treatment —have
deprived Petitioner Tony Moody of his constitutional right to due
process and equal protection under the law.
2. Whether the lower courts fragmented and isolated analysis
of evidence, in contradiction to the totality-of-the-evidence
requirement, warrants this Court's intervention to clarify and correct
the misapplication of both state and federal principles governing
retaliatory employment actions.
3. Whether these errors, by undermining the statutory
safeguards provided by Ohio Revised Code §§4112.02(1),
4112.05(B)(1), and 4112.99, not only imperil Petitioner's individual
rights but also threaten the integrity of public policy designed to
protect employees from arbitrary and retaliatory discipline.
Whether the cumulative errors in applying established antiretaliation standards have deprived Petitioner of constitutional due process and equal protection rights