Thomas Cusack Co. v. City of Cincinnati

9 Ohio N.P. (n.s.) 466
CourtCourt of Common Pleas of Ohio, Hamilton County
DecidedMarch 15, 1910
StatusPublished

This text of 9 Ohio N.P. (n.s.) 466 (Thomas Cusack Co. v. City of Cincinnati) is published on Counsel Stack Legal Research, covering Court of Common Pleas of Ohio, Hamilton County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Thomas Cusack Co. v. City of Cincinnati, 9 Ohio N.P. (n.s.) 466 (Ohio Super. Ct. 1910).

Opinion

O’Connell, J.

These causes come into this court on error to the judgment of-the police court of Cincinnati. The plaintiffs in error were fined for the violation of certain of the items of the building ordinance of Cincinnati appertaining to the construction and maintenance and repair of bill boards.

Counsel for the city and for the plaintiffs have submitted briefs showing great care and painstaking research into the decisions governing this subject of bill boards.

There are apparently conflicts in these decisions, but these conflicts are in large measure due to the interpretation of the word “reasonable” which is given by the different courts in construing the manner and mode of the construction of' bill boards.

' It is conceded that the power and authority of council to regulate bill -boards as well as other structures falls under what is known -as the police power of the state; that power which inheres in every community to converse its safety and welfare.

The Supreme Court of the United States has decided that the question of a proper and reasonable regulation or ordinance passed by a municipal council as being a proper exercise of the police power is a question to be decided by the courts.

In Yates v. Milwaukee, 10 Wallace, 497, we find the following at page 505:

“But the mere declaration by the city council of Milwaukee that a certain structure was an encroachment or obstruction did not make it so, nor could such declaration malee It a nuisance unless it in fact had that character. It is a doctrine not to be tolerated in this country, that a municipal corporation, without any general laws either of the city or the state within which a given structure can he shown to he a nuisance, can, by its mere declaration that it is one, subject it to removal by any person supposed to be aggrieved, or even by the city itself. This would place every house, every business, and all the property of the city at the uncontrolled will of the temporary local authorities.”

In the case of In re Wilshire, 103 Fed. Rep., 620, at page 622, we find the following language:

“Laws enacted in, the exercise of the police power, however, whether by a municipal corporation acting in pursuance of the [468]*468laws of a state, or by a state itself, must be reasonable, and are always subject to the provisions of both the federal and the state constitutions and they are always subject to judicial scrutiny.’’

The general trend of decisions in matters of this kind as shown in a decision which covers a number of items of the section of the ordinance under consideration, is very well expressed in the following language from the Supreme Court of North Carolina, as given in State v. Whitlock, 63 S. E. Rep., 123:

‘ It is undoubtedly within the power of the corporate authorities of the city of Ashville to prohibit the erection of insecure bill boards or other structures along the edge of public streets or so near as to be a menace, to require the owners to maintain all structures' so located in a secure condition, and to provide for inspection and removal at the owner’s expense, if condemned as dangerous. The city authorities may also adopt regulations as to the manner of construction of bill boards so as to insure safety to the passers-by; but the prohibition of structures upon the lot line, however safe they may be, is an unwarrantable invasion of a private right, and is so held to be by all the courts which have passed upon the precise question, as we are now advised.”

The municipal authorities of Cincinnati have this same right, but no greater right.

As bearing on this same attitude of the courts with reference to regulations -attempted under the police power, in the ease of Crawford v. Topeka, 51 Kansas, 756, at page 762, we find the following language with regard to certain portions of an ordinance regulating the construction of bill boards:

“All statutory restrictions of the use of property are imposed upon the theory that they are necessary for the safety, health or comfort of the public; but a limitation without reason or necessity can not be enforced. In what way can the erection of a safe structure for advertising purposes, near the front of a lot, endanger public safety any more than a like structure for some other lawful purpose? Why does the posting or painting of an advertisement upon a secure wall or structure render it insecure? An owner may desire to use a structure or bill board for an inclosure of his lot, as well as for posting advertisements. In one instance that was the desire and purpose of the owner in this case. If the wall or inelosure was ten feet high, then under the ordinance the owner would be required to set it back fifteen feet [469]*469from the front of the lot. What reason is there for the surrender or loss of the use of that portion of the lot? Or why should the pasting of a piece of paper upon a secure inelosure make such a loss necessary? Although the police power is a broad one, it is not without limitations, and a -secure structure which is not an infringement upon the public safety, and is not a nuisance, can not be made one by legislative fiat, and then prohibited.”

While the city council has the undoubted right to pass ordinances regulating the construction and maintenance of bill boards whether erected upon public or private property, yet such legislation must be prospective in character and can not be retroactive. This has been decided by the federal courts- in which such actions have been litigated.

In Whitmier v. Buffalo, 118 Fed. Rep., 773, at page 776, we find the following language:

“The enactment prohibiting the erection of fences and bill boards more than seven feet in height is not unreasonable. # # * The complainant asserts, and it is not controverted, that many of the bill boards now sought by the defendant to be removed were located on private property prior to the enactment of the ordinance. The existing law -declaring bill boards more than seven feet in height as- a common nuisance does not apply to such bill boards or signs. * * * Such structures are not per se illegal by reason of this ordinance, which has been declared valid. The ordinance can not be retroactive. ’ ’

The decisions -cited by the city solicitor wherein ordinances of an apparently retroactive nature were upheld, are found on examination to refer to dwellings and factories wherein further sanitary appliances, fire escapes, etc., were ordered.

Although an owner might have complied with an existing ordinance, yet courts have upheld the compulsory installation of further betterments and .fire escapes under later ordinances when such were found to be essential to the safety and well being of the occupants of the buildings. The facts in such eases are not comparable with the erection of bill boards in and about vacant lots. Such decisions, therefore, are hardly applicable to the case at bar. Hence, any attempt to interfere with existing bill boards except to make them safe and secure would be illegal, provided they complied with the ordinances in force at the time of their erection.

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Related

State v. . Whitlock
63 S.E. 123 (Supreme Court of North Carolina, 1908)

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9 Ohio N.P. (n.s.) 466, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thomas-cusack-co-v-city-of-cincinnati-ohctcomplhamilt-1910.