The waiver doctrine foreclosed the option of an Ohio couple charged by the state civil rights commission with housing discrimination to later seek a remedy through declaratory judgment under the federal Civil Rights Act. Grybosky v. Ohio Civ. Comm., 2011-Ohio-6843, 2011 WL 6938434 (Ohio Ct. App. 11th Dist. Ashtabula County 2011). Sometime prior to September 17, 2008, the Grybosky's, owners of a rental home in Conneaut, Ohio, received two separate visits by "testers" sent by the Ohio Civil Rights Commission (OCRC).
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