S. Euclid v. Fortson

2020 Ohio 187, 151 N.E.3d 1039
CourtOhio Court of Appeals
DecidedJanuary 23, 2020
Docket108268
StatusPublished

This text of 2020 Ohio 187 (S. Euclid v. Fortson) 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
S. Euclid v. Fortson, 2020 Ohio 187, 151 N.E.3d 1039 (Ohio Ct. App. 2020).

Opinion

[Cite as S. Euclid v. Fortson, 2020-Ohio-187.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

CITY OF SOUTH EUCLID, :

Plaintiff-Appellant, : No. 108268 v. :

DEQUAN FORTSON, :

Defendant-Appellee. :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED RELEASED AND JOURNALIZED: January 23, 2020

Criminal Appeal from the South Euclid Municipal Court Case Nos. CRB1800196 and TRD1800721

Appearances:

Michael Loggrasso, South Euclid Law Director, and Brian M. Fallon, Assistant Prosecutor, for appellant.

Eric J. Cherry, for appellee.

LARRY A. JONES, SR., J.:

In this appeal, plaintiff-appellant city of South Euclid (“South

Euclid”) challenges the January 3, 2019 judgment of the South Euclid Municipal

Court granting the motion to dismiss of defendant-appellee Dequan Fortson

(“Fortson”). For the reasons that follow, we affirm. Factual and Procedural History

On March 22, 2018, the South Euclid police effectuated a traffic stop

on Fortson. The parties stipulated that the sole basis of the stop was the officer’s

observation that Fortson was not wearing his seat belt. As a result of the stop,

Fortson was arrested and charged for a violation of a temporary protection order, a

noncompliance suspension, a license forfeiture suspension, and a seat belt

infraction in violation of South Euclid Codified Ordinances 337.27(b)(1).

Fortson filed a motion to suppress. A hearing was held on the motion,

which was converted to a motion to dismiss. Fortson contended that the city’s seat

belt ordinance was an improper use of municipal police power; therefore, the stop

was improper and the evidence gathered as a result of the stop was “fruit of the

poisonous tree.”1 After the hearing, the trial court granted Fortson’s motion to

dismiss. The city now appeals and sets forth the following assignment of error for

our review:

The South Euclid Seat Belt Ordinance 337.27(d) is a proper exercise

of home rule police power that allows a police officer to stop a motorist and issue a

citation based solely on the officer’s observation and no underlying offense need be

observed or cited.

1The “fruit of the poisonous tree” is a judicially created exclusionary rule that provides a remedy to exclude evidence from the government’s case when it has been obtained by the police through an illegal search or seizure in violation of the Fourth Amendment to the United States Constitution. Mapp v. Ohio, 367 U.S. 643, 655, 81 S.Ct. 1684, 6 L.Ed.2d 1081 (1961). Law and Analysis

In 1986, the Ohio legislature enacted a law making it mandatory that

any person operating a motor vehicle on any street or highway in the state wear a

seatbelt. See R.C. 4513.263(B). However, the law does not allow the police to stop

a vehicle for the sole purpose of determining, and/or issuing a citation for, a seat

belt infraction. The statute reads in pertinent part as follows:

Notwithstanding any provision of law to the contrary, no law enforcement officer shall cause an operator of an automobile being operated on any street or highway to stop the automobile for the sole purpose of determining whether a violation * * * of this section has been or is being committed or for the sole purpose of issuing a ticket, citation, or summons for a violation of that nature or causing the arrest of or commencing a prosecution of a person for a violation of that nature, and no law enforcement officer shall view the interior or visually inspect any automobile being operated on any street or highway for the sole purpose of determining whether a violation of that nature has been or is being committed.

R.C. 4513.263(D).

In 2012, the city of South Euclid enacted a seat belt law, South Euclid

Codified Ordinances 337.27(d). The city’s ordinance provides as follows:

Any law enforcement officer with reasonable suspicion may cause an operator of an automobile being operated on any street or highway to stop the automobile for the sole purpose of determining whether a violation of division (b) of this section has been or is being committed or for the sole purpose of issuing a ticket, citation, or summons for the violation or for causing the arrest of or commencing a prosecution of a person for the violation. Any law enforcement officer may view the interior or visually inspect any automobile being operated on any street or highway for the sole purpose of determining whether the violation has been or is being committed. South Euclid contends that its ordinance was an exercise of police

power pursuant to its authority to self-govern and, therefore, was permissible under

the home-rule provision of the Ohio Constitution. The home-rule provision is found

in Section 3 of Article XVIII of the Ohio Constitution and provides: “Municipalities

shall have authority to exercise all powers of local self-government and to adopt and

enforce within their limits such local police, sanitary and other similar regulations,

as are not in conflict with general laws.” (Emphasis added.)

The Ohio Supreme Court has held that a law is a general law for home-

rule analysis if it (1) is part of a statewide and comprehensive legislative enactment,

(2) applies to all parts of the state alike and operates uniformly throughout the state,

(3) sets forth police, sanitary, or similar regulations, rather than purport only to

grant or limit legislative power of a municipal corporation to set forth police,

sanitary, or similar regulations, and (4) prescribes a rule of conduct upon citizens

generally. Canton v. State, 95 Ohio St.3d 149, 2002-Ohio-2005, 766 N.E.2d 963,

¶ 21. A state statute takes precedence over a local ordinance when (1) the ordinance

is in conflict with the statute, (2) the ordinance is an exercise of the police power,

rather than of local self-government, and (3) the statute is a general law. Ohio Assn.

of Private Detective Agencies, Inc. v. N. Olmsted, 65 Ohio St.3d 242, 244-245, 602

N.E. 2d 1147 (1992).

Upon review, Ohio’s seat belt law is a general law that takes

precedence over South Euclid’s ordinance. It is a statewide law, applies uniformly

throughout the state, sets forth a police regulation, and prescribes conduct on Ohio citizens. Further, Ohio and the city’s laws are in conflict. We are not persuaded

otherwise by the city’s reliance on Dublin v. State, 188 Ohio Misc.2d 18, 2002-Ohio-

2431, 769 N.E.2d 436 (M.C.), for the proposition that the power to enact police,

sanitary, and other similar regulation falls under the auspices of local self-

government.

In Dublin, two Columbus-area suburban cities sued the state of Ohio

seeking a declaration that statutes governing the use of public ways by public utilities

were unconstitutional. The issue in Dublin related to the regulation of cable line

installation along public roadways in the municipalities. The municipal regulation

was concerned with providing municipal residents low-cost cable service and

managing municipal roadways for the benefit of the municipalities’ residents.

The cities contended that R.C. Chapter 4939, which governs public

utilities, was unconstitutional because, among other things, it deprived

municipalities of their home rule powers under the Ohio Constitution, and it did not

operate uniformly across the state as required under the Ohio Constitution. The

Dublin court found that R.C. Chapter 4939 did not violate the uniformity clause

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Related

Mapp v. Ohio
367 U.S. 643 (Supreme Court, 1961)
City of Dublin v. State
2002 Ohio 2431 (Court of Common Pleas of Ohio, Franklin County, Civil Division, 2002)
Canton v. State
2002 Ohio 2005 (Ohio Supreme Court, 2002)

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2020 Ohio 187, 151 N.E.3d 1039, Counsel Stack Legal Research, https://law.counselstack.com/opinion/s-euclid-v-fortson-ohioctapp-2020.