Jurek v. Ohio Motor Vehicle Dealers Board

651 N.E.2d 3, 99 Ohio App. 3d 437, 1994 Ohio App. LEXIS 5273
CourtOhio Court of Appeals
DecidedDecember 5, 1994
DocketNo. 66373.
StatusPublished
Cited by3 cases

This text of 651 N.E.2d 3 (Jurek v. Ohio Motor Vehicle Dealers Board) 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
Jurek v. Ohio Motor Vehicle Dealers Board, 651 N.E.2d 3, 99 Ohio App. 3d 437, 1994 Ohio App. LEXIS 5273 (Ohio Ct. App. 1994).

Opinions

Dyke, Judge.

Plaintiff-appellant, Frederick K. Jurek, Jr., appeals from a judgment of the court of common pleas which affirmed the denial of his used motor vehicle dealer license by the Ohio Motor Vehicle Dealers Board, defendant-appellee herein, due to a felony conviction occurring after December 8, 1986. In a single assignment of error, appellant claims that the trial court erred in affirming the denial of his application because R.C. 4517.12(B) and Ohio Adm.Code 4501:1-3-09, which deny licenses to felons convicted after December 8,1986 but allegedly permit licensure to felons convicted before that date, violate his right to equal protection. Upon review, we find appellant’s assignment of error to be without merit. The judgment of the trial court is affirmed.

The facts of the instant case are undisputed. On September 16,1991, appellant pled guilty to two counts of theft (R.C. 2913.02), both felonies of the fourth degree. On April 27, 1992, the Registrar of the Bureau of Motor Vehicles denied appellant’s application for renewal, as such application required the appellant to disclose felony convictions occurring after 1986. On May 8, 1992, appellaht appealed the denial. On September 29, 1992, subsequent to a hearing, appellee affirmed the registrar’s denial. On October 1, 1993, the trial court affirmed appellee’s denial and the instant appeal followed.

“The trial court erred as a matter of law in upholding the denial of Jurek’s license denial because R.C. § 4517.12(B) and O.A.C. § 4501:1-3-09 violate Jurek’s fundamental right to equal [protection] of the law as guaranteed by Article I, § 2 of the Ohio Constitution, and the Fourteenth Amendment to the United States Constitution.”

In his sole assignment of error, appellant claims that R.C. 4517.12(B) and Ohio Adm.Code 4501:1-3-09 violate his right to equal protection because they treat felons differently, to wit, they automatically deny licenses to felons convicted after December 8, 1986 but allegedly permit licenses to felons convicted prior to that date. 1 Appellant also claims that the above-cited statute and administra *439 tive rule are not rationally related to the legitimate state interest of protecting consumers from fraudulent or dishonest sales practices because they classify on the basis of date of conviction rather than on the seriousness of the felony involved. Accordingly, appellant argues that murderers and rapists who were convicted prior to 1986 will be able to obtain licenses while individuals convicted of lesser felonies after 1986 will be denied licenses. Appellant’s arguments are unpersuasive.

“In adjudicating an equal protection claim against state action which discriminates among classes, a mere rationality test is to be employed where neither a fundamental interest nor a suspect class is involved. Massachusetts Bd. of Retirement v. Murgia (1976), 427 U.S. 307, 312 [96 S.Ct. 2562, 2566, 49 L.Ed.2d 520, 524]. Thus, under this test, a classification must be upheld as constitutionally permitted unless its assailant demonstrates that it is not rationally related to the furthering of any legitimate state interest. See, e.g., Vance v. Bradley (1979), 440 U.S. 93, 96-97 [99 S.Ct. 939, 942-943, 59 L.Ed.2d 171, 175-176].” (Emphasis added.) State ex rel. Ohio Civ. Serv. Emp. Assn. v. Stackhouse (1981), 1 Ohio App.3d 121, 123, 1 OBR 428, 430, 439 N.E.2d 936, 938.

“As a practical matter, the rational basis test requires that a legislative classification, albeit imperfect or discriminatory, will not be set aside if any set of facts reasonably may be conceived to justify it. Evans v. Chapman (1986), 28 Ohio St.3d 132,135 [28 OBR 228, 231, 502 N.E.2d 1012, 1015], citing McGoivan v. Maryland (1961), 366 U.S. 420, 425-426 [81 S.Ct. 1101, 1105, 6 L.Ed.2d 393, 398-399].” (Emphasis added.) Stasiuk v. Cleveland (Apr. 28, 1988), Cuyahoga App. No. 53718, unreported at 9-10, 1988 WL 39293, appeal dismissed as having been improvidently allowed (1989), 43 Ohio St.3d 612, 539 N.E.2d 633, upon remand (1991), 72 Ohio App.3d 35, 593 N.E.2d 427.

Appellant does not dispute that the “rational basis test” is the appropriate level of scrutiny to be applied to this matter of economic regulation. Nor does he dispute the fact that the appellee has a legitimate state interest in protecting citizens from dishonest and or fraudulent sales practices. Appellant merely asserts that these laws are unconstitutional because they treat felons differently, using date of conviction rather than seriousness of conviction as classifying *440 criteria. Appellant’s argument is unpersuasive because it fails to acknowledge the fact that the above-cited statutory scheme furthers a legitimate state interest.

R.C. 4517.12(B) and Ohio Adm.Code 4501:1-3-09 operate to automatically deny licenses to recently convicted felons. Such denial clearly reduces the number of felons engaging in automotive sales transactions. Consequently, the legitimate state interest of reducing the risk of consumer exposure to possibly unscrupulous sales practices is effectuated. That appellee has sought to further this interest by imposing a temporal priority to license denial does not violate appellant’s equal protection rights, as appellee has demonstrated that such prioritization is rationally related to reducing consumer exposure to unscrupulous motor vehicle dealers.

Appellee argues in its brief that applicants who have committed felonies prior to 1986 are better risks to hold dealer licenses than applicants who have committed felonies after 1986. Appellee reasons that the greater the period of time between a felon’s conviction date and his or her license application date, the more likely it is that he or she is not a habitual felon and has had time for rehabilitation. Appellee also argues that absence of a conviction after 1986 demonstrates that the applicant has been able to live in compliance with the law for a substantial period of time. We agree. Moreover, awarding recently convicted felons licenses to pursue lucrative careers in the field of automotive sales would be against public policy. We find R.C. 4517.12(C) and Ohio Adm. Code 4501:1-3-09, which automatically deny dealer licenses to recently convicted felons, to be rationally related to furthering the legitimate state interest of reducing consumer exposure to fraudulent or dishonest automotive sales practices.

Appellant’s argument that temporal classification permits murders and rapists convicted before December 8, 1986 to obtain licenses is unfounded. R.C. 4517.33 provides for the suspension and/or revocation of licenses regardless of the type of felony or the date of conviction. 2 R.C. 4517.33 provides in relevant part that':

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651 N.E.2d 3, 99 Ohio App. 3d 437, 1994 Ohio App. LEXIS 5273, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jurek-v-ohio-motor-vehicle-dealers-board-ohioctapp-1994.