Columbus v. State

2025 Ohio 2408
CourtOhio Court of Appeals
DecidedJuly 8, 2025
Docket24AP-333
StatusPublished

This text of 2025 Ohio 2408 (Columbus v. State) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Columbus v. State, 2025 Ohio 2408 (Ohio Ct. App. 2025).

Opinion

[Cite as Columbus v. State, 2025-Ohio-2408.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

City of Columbus et al., :

Plaintiffs-Appellees, : No. 24AP-333 v. : (C.P.C. No. 24CV-2865)

State of Ohio, : (REGULAR CALENDAR)

Defendant-Appellant, :

Ohio Department of Health et al., :

Defendants-Appellees. :

D E C I S I O N

Rendered on July 8, 2025

On brief: Zach Klein, City Attorney, Richard N. Coglianese, Matthew D. Sturtz, Aaron D. Epstein, and Micah L. Berman, for plaintiff-appellee City of Columbus. Argued: Richard N. Coglianese.

On brief: McTigue & Colombo LLC, Donald J. McTigue, and Stacey N. Hauff; Campaign for Tobacco-Free Kids, Dennis A. Henigan and Connor Fuchs, Amici Curiae for African American Tobacco Control Leadership Council; American Cancer Society Cancer Action Network; American Heart Association; American Lung Association; American Medical Association; Association of Ohio Health Commissioners; Campaign for Tobacco-Free Kids; National LGBTQI+ Cancer Network; Ohio Chapter, American Academy of Pediatrics; Ohio State Medical Association; Parents Against Vaping E- Cigarettes; Preventing Tobacco Addiction Foundation; Public Health Law Center; The Breathing Association; The Center for Black Health and Equity; and Truth Initiative, in support of plaintiffs-appellees. No. 24AP-333 2

On brief: Dickinson Wright PLLC, Jonathan R. Secrest, David A. Lockshaw, Jr., and Kevin D. Shimp, for appellant State of Ohio. Argued: Jonathan R. Secrest.

On brief: Vorys, Sater, Seymour and Pease LLP, David A. Froling, Michael C. Griffaton, and Jeffrey Allen Miller, for Amici Curiae The Ohio Council of Retail Merchants, Ohio Grocers Association, Ohio Energy and Convenience Association, and Ohio Chamber of Commerce in support of appellant.

APPEAL from the Franklin County Court of Common Pleas

LELAND, J. {¶ 1} After his second veto of R.C. 9.681, Mike DeWine, Governor of Ohio, expressed his aversion to the General Assembly’s attempt to preclude all Ohio municipalities from regulating tobacco: In the absence of an effective and comprehensive statewide flavored tobacco ban (including menthol) — which is this administration’s preferred policy approach — local government bans are essential because they reduce access to flavored tobacco and nicotine alternative products and interrupt the cycle of addiction. The removal of local regulation would encourage youth nicotine addiction and immediately undo years of progress to improve public health, which is why a similar provision was previously vetoed.

(Am. Compl. at 71.) This sort of interaction between state and local regulatory power has long been understood. Horace G. Redington, a delegate to the 1912 Constitutional Convention of Ohio, succinctly explained this interplay to the convention: “In case the state neglects to pass proper police and sanitary regulations, the city may do so, and if the state then passes laws beyond and more strict than the city laws, the city laws are nullified.” 2 Smith, Proceedings and Debates of the Constitutional Convention of the State of Ohio, 1468 (1913). In overriding the governor’s veto and enacting R.C. 9.681, the General Assembly means to preempt local regulation of tobacco. {¶ 2} Defendant-appellant State of Ohio seeks reversal of a trial court order finding R.C. 9.681 violative of Article XVIII, Section 3 of the Ohio Constitution. Along with the cities of Athens, Barberton, Bexley, Cincinnati, Cleveland, Dublin, Gahanna, Grandview Heights, Heath, Hilliard, Kent, North Ridgeville, Oberlin, Oxford, Reynoldsburg, No. 24AP-333 3

Springfield, Toledo, Upper Arlington, Whitehall, and Worthington, plaintiff-appellee City of Columbus (hereinafter referred to as “Columbus”) contends its ordinance banning the sale of flavored tobacco products is a valid exercise of its home rule authority. I. Facts and Procedural History {¶ 3} On December 12, 2022, Columbus passed Ordinance 3253-2022 (“ordinance”). The ordinance authorized the Columbus Department of Public Health to enforce the city’s tobacco laws and health code, established a system of civil penalties including fines and license revocation for violating tobacco regulations, and banned the sale of flavored tobacco products. Columbus set January 1, 2024 as the effective date of its sales ban. The ordinance cited the need to protect children from the harmful and addictive effects of flavored tobacco products and noted such products disproportionately affect black smokers. Columbus asserted it passed this ordinance to protect the health, safety, and welfare of its residents. The other plaintiffs-appellees likewise passed ordinances regulating tobacco (hereinafter Columbus and its co-plaintiffs collectively referred to as “appellees”). {¶ 4} Just two days after Columbus passed its ordinance, the Senate Ways and Means Committee on December 14, 2022 amended H.B. No. 513 to enact a new section of law in the Revised Code, R.C. 9.681, to prohibit all local regulation of tobacco products. The General Assembly passed Sub.H.B. No. 513 that same day, December 14, 2022. On January 5, 2023, the governor vetoed the bill. The governor’s veto message explained: Increased tobacco usage is also known as a cause of increased health care costs, including health care costs paid for by the taxpayers of the State of Ohio.

A local government that bans flavored tobacco products, that are often marketed specifically to appeal to youth, may be doing so to discourage youth tobacco use. . . . Flavors, including menthol, help mask the harshness of tobacco making it easier for kids to become addicted.

(June 5, 2023 Veto Message.) On June 30, 2023, the General Assembly passed Am.Sub.H.B. No. 33, a budget bill that included R.C. 9.681’s prohibition on local regulation of tobacco products. On July 3, 2023, the governor again vetoed the R.C. 9.681 portion of the bill. However, by a House vote on December 13, 2023 and a Senate vote on January 24, 2024, the General Assembly elected to override the governor’s second veto of R.C. 9.681. No. 24AP-333 4

{¶ 5} The text of R.C. 9.681 provides as follows: (A) As used in this section, “tobacco product” and “alternative nicotine product” have the same meanings as in section 2927.02 of the Revised Code.

(B) The regulation of tobacco products and alternative nicotine products is a matter of general statewide concern that requires statewide regulation. The state has adopted a comprehensive plan with respect to all aspects of the giveaway, sale, purchase, distribution, manufacture, use, possession, licensing, taxation, inspection, and marketing of tobacco products and alternative nicotine products. No political subdivision may enact, adopt, renew, maintain, enforce, or continue in existence any charter provision, ordinance, resolution, rule, or other measure that conflicts with or preempts any policy of the state regarding the regulation of tobacco products or alternative nicotine products, including, without limitation, by:

(1) Setting or imposing standards, requirements, taxes, fees, assessments, or charges of any kind regarding tobacco products or alternative nicotine products that are the same as or similar to, that conflict with, that are different from, or that are in addition to, any standard, requirement, tax, fee, assessment, or other charge established or authorized by state law;

(2) Lowering or raising an age requirement provided for in state law in connection with the giveaway, sale, purchase, distribution, manufacture, use, possession, licensing, taxation, inspection, and marketing of tobacco products or alternative nicotine products;

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Rubin v. United States
449 U.S. 424 (Supreme Court, 1981)
Connecticut National Bank v. Germain
503 U.S. 249 (Supreme Court, 1992)
City of Cleveland v. State
2010 Ohio 6318 (Ohio Supreme Court, 2010)
City of Cleveland v. State
2014 Ohio 86 (Ohio Supreme Court, 2014)
Wilson v. Kasich
2012 Ohio 5367 (Ohio Supreme Court, 2012)
State v. Addison, Unpublished Decision (9-28-2004)
2004 Ohio 5154 (Ohio Court of Appeals, 2004)
City of Youngstown v. Brown
168 N.E. 844 (Ohio Supreme Court, 1929)
City of Akron v. Scalera
19 N.E.2d 279 (Ohio Supreme Court, 1939)
Dayton v. State (Slip Opinion)
2017 Ohio 6909 (Ohio Supreme Court, 2017)
State v. Williams
2018 Ohio 974 (Ohio Court of Appeals, 2018)
State v. Lawson
2020 Ohio 3004 (Ohio Court of Appeals, 2020)
United States v. Wiltberger
18 U.S. 76 (Supreme Court, 1820)
Village of West Jefferson v. Robinson
205 N.E.2d 382 (Ohio Supreme Court, 1965)
Garcia v. Siffrin Residential Ass'n
407 N.E.2d 1369 (Ohio Supreme Court, 1980)
Downing v. Cook
431 N.E.2d 995 (Ohio Supreme Court, 1982)
Fondessy Enterprises, Inc. v. City of Oregon
492 N.E.2d 797 (Ohio Supreme Court, 1986)
City of Rocky River v. State Employment Relations Board
539 N.E.2d 103 (Ohio Supreme Court, 1989)
Village of Linndale v. State
85 Ohio St. 3d 52 (Ohio Supreme Court, 1999)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 2408, Counsel Stack Legal Research, https://law.counselstack.com/opinion/columbus-v-state-ohioctapp-2025.