## Facts

- General Motors operated an employee suggestion plan under which a committee decided eligibility and award amounts, and committee decisions were final.
- The plan stated that suggestions were not submitted in confidence.
- Michael Joyce, a nonsupervisory employee, submitted a written suggestion to reduce scrap in his department.
- The next day, the committee returned Joyce’s submission as a “duplicate” of a suggestion submitted the same day by Donald Halsey, a supervisory employee; Halsey’s submission was also marked duplicate.
- Joyce and Halsey had discussed their ideas with others before submission; evidence indicated Halsey learned of the idea through workplace conversations.
- After investigation, the committee awarded Halsey $12,573.13 for the adopted suggestion and indicated Joyce would not have received an award if Halsey’s suggestion were rejected.
- Halsey gave $5,000 to Donald Tackett, the supervisor over Joyce’s department, described as a gift for assistance.
- Joyce sued GM, Halsey, and Tackett alleging wrongful appropriation and conspiracy; his primary theory was conversion of his idea and related rights under the suggestion plan.
- At the close of Joyce’s evidence, the trial court directed a verdict for defendants, reasoning that unprotected ideas could not be converted.
- The court of appeals reversed, treating the trial court ruling as akin to a Civ.R. 12(B)(6) dismissal.
- The Supreme Court of Ohio reviewed and reversed the court of appeals.

## Issues

1. Whether the appellate court erred by treating the trial court’s ruling as a Civ.R. 12(B)(6) disposition rather than a directed verdict under Civ.R. 50(A) based on trial evidence.
2. Whether an idea submitted under an employer’s suggestion plan, absent statutory protection or a confidential relationship, constitutes property that can be converted.

## Decision

- The Supreme Court of Ohio held the trial court’s ruling was a directed verdict, and the appellate court should have examined the record to identify the basis for judgment.
- The court held that ideas are not property unless expressed in a legally protected manner.
- Because Joyce’s suggestion was not legally protected and was not submitted in confidence, it could not support a conversion claim.
- The court reversed the court of appeals and reinstated judgment for GM, Halsey, and Tackett.

## Legal Principles

- A reviewing court must examine the entire journal entry and proceedings when necessary to determine the grounds for the lower court’s judgment.
- A directed verdict under Civ.R. 50(A) is decided on the evidence admitted at trial; a Civ.R. 12(B)(6) motion tests the pleadings before trial.
- Conversion requires an identifiable, legally recognized property interest.
- Ideas, standing alone, are not property and are not subject to conversion unless expressed in a legally protected form (e.g., patent, copyright, trademark) or protected by a duty arising from a confidential, fiduciary, or special contractual relationship.
- Where an employer plan disclaims confidentiality and the idea is openly discussed, the submitter lacks a property interest in the idea for conversion purposes.

## Conclusion

The Ohio Supreme Court reinstated a directed verdict for the defendants, holding that an employee’s unprotected idea submitted under a nonconfidential suggestion plan is not “property” and therefore cannot be the subject of a conversion claim.


Joyce v. Gen. Motors Corp., 49 Ohio St. 3d 93, 551 N.E.2d 172 (Ohio 1990)